ASOS, Boohoo, and George at Asda: What the CMA’s Greenwashing Undertakings Mean for Every UK Business in 2026

ASOS had its “Responsible edit.” Boohoo ran a “Ready for the Future” range. George at Asda marketed “George for Good.” Between them, the CMA said, the three retailers make over GBP 4.4 billion a year from UK fashion sales.

The CMA launched formal investigations into all three in July 2022 after an initial review of the fashion sector. Its concerns centred on vague green language, on unclear criteria for which products qualified for green ranges, and on how some ranges were displayed. Nearly two years later, in March 2024, all three signed undertakings. The CMA made no finding that they had broken consumer law, and no fines followed. But the retailers agreed to overhaul how they display, describe, and prove their environmental claims, and the CMA published an open letter urging the whole fashion sector to review its own claims.

CMA Chief Executive Sarah Cardell said the action means millions of shoppers can now have confidence in the green claims they see from these brands. The case matters well beyond fashion. It shows how the CMA reads the law, and the enforcement environment has since become tougher.

What the CMA Actually Looked At

The investigation covered three areas of concern.

Vague and potentially misleading language. Range names such as “Responsible edit,” “Ready for the Future,” and “George for Good” can suggest comprehensive environmental credentials. The reality of what qualified a product for inclusion can be narrower, and the CMA’s concern was that shoppers could not see how narrow.

Unclear product criteria. Customers may assume products in these ranges meet meaningful environmental standards. The CMA’s view was that the criteria for inclusion must be clearly set out, including any minimum requirements, so shoppers can judge for themselves.

How claims are displayed and promoted. Imagery, labels, and product pages can mislead by omission, even when each individual statement is technically defensible.

None of this concerned a specific environmental statute. It concerned consumer protection law. The Consumer Protection from Unfair Trading Regulations 2008 made it unlawful to mislead customers about the characteristics of a product, and environmental claims fall under it. From April 6, 2025, the Digital Markets, Competition and Consumers Act 2024 replaced those rules with a regime the CMA can enforce directly.

What the Three Retailers Agreed to Do

The CMA did not fine or prosecute them. It secured commitments that now function as a compliance template for every UK business making environmental claims.

All green claims must be accurate and not misleading. Statements about materials in green ranges must be specific and clear, such as “recycled” or “organic,” rather than ambiguous terms such as “eco,” “responsible,” or “sustainable.” If a product contains recycled fabric, say so with the specifics.

Criteria for green ranges must be transparent. The criteria used to decide which products enter an environmental collection must be clearly set out, with any minimum requirements. Where a range has a target, the information should include what the target aims to achieve, the date by which it is expected to be met, and how the company will pursue it.

Display and promotion must not mislead. The undertakings cover how the retailers display, describe, and promote their green credentials, so imagery and product pages must support what the claims actually say.

These commitments are enforceable. If a retailer breached them, the CMA could ask a court to enforce the undertakings. And the sector-wide open letter signalled that other businesses should treat them as a benchmark.

Which UK Regulations Does a Business Like This Face?

The CMA case focused on greenwashing under consumer protection law. But any large UK retailer faces a wider set of environmental obligations. The following sections describe those obligations in general terms. We make no claim about how any of the named retailers complies with them.

Mandatory SECR Carbon Reporting

Streamlined Energy and Carbon Reporting applies to large UK companies and LLPs as defined in the Companies Act, and to quoted companies. Those organisations must disclose UK energy consumption, Scope 1 and 2 GHG emissions, at least one intensity ratio, and energy efficiency actions in their annual directors’ report. The Companies Act size tests combine employee, turnover, and balance sheet criteria, and the government uprated the turnover and balance sheet limits in 2025, so check the current figures.

Directors who sign off on materially misleading SECR disclosures face personal liability under the Companies Act 2006. Auditors flag non-compliant SECR disclosures, which can result in qualified audit opinions. The practical lesson from the CMA case is consistency: the carbon numbers in a company’s annual report, the claims in its marketing, and the data behind both must tell the same story.

UK TCFD Requirements and UK SRS

UK premium-listed companies, large private companies (500+ employees and GBP 500M+ turnover), and financial services firms must publish TCFD-aligned climate disclosures. TCFD disclosures cover governance, strategy, risk management, and metrics and targets, including Scope 1, 2, and, where relevant, Scope 3 emissions.

The next step is the UK Sustainability Reporting Standards, published on February 25, 2026 for voluntary use. The FCA has proposed making them mandatory for listed companies from accounting periods starting on or after January 1, 2027, and the government plans to consult on large private companies.

UK Packaging EPR

Online and high-street retailers alike handle large volumes of packaging. The UK Packaging Extended Producer Responsibility scheme requires businesses handling over 50 tonnes of packaging per year with a turnover of over GBP 2 million to register, report packaging data, and pay fees that fund recycling infrastructure.

Non-UK e-commerce businesses selling packaged goods to UK consumers face the same obligations. Non-compliance risks fines and exclusion from compliance schemes, which effectively bars a business from legally placing packaging on the UK market.

CMA Green Claims Code Enforcement

This is where the three retailers’ case sits. The CMA published its Green Claims Code in September 2021. It sets six principles every environmental claim must meet:

• Claims must be truthful and accurate
• Claims must be clear and unambiguous
• Claims must not omit or hide important information
• Comparisons must be fair and meaningful
• Claims must consider the full life cycle of the product
• Claims must be substantiated with robust evidence

The Code was guidance when published. The Digital Markets, Competition and Consumers Act 2024 then gave the CMA direct enforcement powers over consumer law. Since April 6, 2025, it can fine businesses up to GBP 300,000 or 10% of global annual turnover, whichever is higher, without going to court.

The retailers’ investigation began in July 2022 and ended in March 2024, before these powers existed. Businesses operating in 2026 face a different enforcement landscape. Any UK business making sustainability claims in marketing, on packaging, or in investor communications now faces direct enforcement risk. Generic claims without specific substantiation are the CMA’s primary target.

What Happens If Your Business Fails UK Environmental Compliance

The three retailers’ case ended in undertakings, not fines. But that was 2024. The enforcement environment in 2026 is different.

• CMA greenwashing penalties: Fines up to GBP 300,000 or 10% of global annual turnover under the Digital Markets, Competition and Consumers Act 2024. Enforcement orders requiring removal or correction of claims. Public investigation announcements that create immediate reputational damage
• Environmental permit breaches: Fines are unlimited for serious violations. Permit revocation forces operational shutdown. Director imprisonment applies to knowing or reckless violations. The Environment Agency, SEPA, and Natural Resources Wales actively enforce permits
• UK ETS non-compliance: GBP 100 per tonne of excess emissions, increasing annually. Persistent non-compliance triggers public naming and tightened permit conditions
• SECR failures: Directors who sign misleading strategic reports face personal liability. The FRC can require restatement of accounts. Auditors must qualify their opinion on non-compliant strategic reports
• Packaging EPR non-registration: Fines and potential import restrictions. Retailers discovering their suppliers are non-registered can and do terminate commercial relationships to protect their own compliance

For a comprehensive view of ESG consequences across jurisdictions, see our guide to penalties for ESG non-compliance and our UK environmental regulations guide.

How UK Businesses Can Actually Comply in 2026

The CMA’s case provides a compliance roadmap. It is not a story of fines, but it illuminates every UK environmental obligation that businesses face.

• Step 1: Audit green claims per the CMA Green Claims Code. Apply all six principles to sustainability claims in marketing and packaging. Remove or substantiate claims before CMA contact. Generic terms like “sustainable,” “eco-friendly,” and “carbon neutral” require specific, verifiable evidence.
• Step 2: Publish the criteria behind any green range. If you run a “responsible” or “sustainable” collection, set out the inclusion criteria and minimum requirements where shoppers can see them
• Step 3: Determine SECR applicability. Check employee count, turnover, and balance sheet against the current Companies Act size tests. If you are a large company or LLP, begin energy and carbon data collection now for your current financial year
• Step 4: Assess UK TCFD and UK SRS obligations. Premium-listed companies, large private companies (500+ employees, GBP 500M+ turnover), and financial services firms must publish TCFD-aligned climate disclosures. Align with ISSB IFRS S2 for forward compatibility
• Step 5: Register under UK Packaging EPR. If you handled 50+ tonnes of packaging in the relevant year and have GBP 2M+ turnover, register as a packaging producer and join a compliance scheme. This applies to non-UK businesses selling packaged goods to UK consumers
• Step 6: Publish your Modern Slavery Act statement. If annual turnover exceeds GBP 36M and you supply goods or services in the UK, publish your annual statement on the Home Office registry
• Step 7: Review all environmental permits and UK ETS status. Confirm compliance with Environment Agency, SEPA, or Natural Resources Wales permits and check expiry dates. If you operate covered industrial facilities in Great Britain, confirm allocation status and plan annual allowance surrender

UK Environmental Compliance Checklist (2026)

• Audit all green claims against the CMA Green Claims Code
• Remove or substantiate all generic environmental terms
• Publish the criteria and minimum requirements behind any green product range
• Assess SECR applicability against the current Companies Act size tests
• Begin energy and carbon data collection for SECR if in scope
• Assess UK TCFD and UK SRS applicability (listed status, company size, financial services)
• Register under UK Packaging EPR if above thresholds
• Publish Modern Slavery Act statement if above GBP 36M turnover
• Review all environmental permits for compliance and expiry
• Confirm UK ETS participation status if operating covered facilities
• Check Plastic Packaging Tax obligations for packaging with less than 30% recycled content
• Assess Biodiversity Net Gain requirements for development projects in England

ASOS, Boohoo, and George at Asda together make over GBP 4.4 billion a year from UK fashion sales. They employ thousands of people and run sophisticated supply chains. And the CMA still took the view, after a nearly two-year investigation, that their environmental claims needed to change. The undertakings they signed in March 2024 did not just alter how three brands market clothing. They set a benchmark for every UK business making environmental claims.

UK environmental regulations in 2026 form an actively enforced framework. SECR and TCFD create disclosure obligations. Packaging EPR creates financial obligations. The CMA enforces green claims with fines up to 10% of turnover. The Environment Agency enforces permits with unlimited fines in court. Systematic compliance is the only rational response.

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Frequently Asked Questions

What environmental regulations apply to UK businesses in 2026?

UK businesses face several mandatory regulations. These include SECR carbon reporting for large companies and LLPs as defined in the Companies Act. They also include UK TCFD climate risk disclosures for listed companies and large financial firms, with UK SRS proposed for listed companies from 2027. Additionally, UK Packaging EPR fees apply to businesses handling 50+ tonnes of packaging. Modern Slavery Act statements are required for businesses with a turnover of GBP 36M+ supplying the UK. Environmental Permitting Regulations apply to operations above certain thresholds. UK ETS covers the industrial and energy sectors. UK REACH involves chemical manufacturers and importers. Lastly, CMA Green Claims Code enforcement is for all businesses making environmental claims.

What is the CMA Green Claims Code, and what claims does it prohibit?

The CMA Green Claims Code sets six principles that all environmental claims must satisfy. It does not prohibit specific terms. It requires every claim to be truthful and unambiguous. Claims must also be substantiated with robust evidence and not be misleading by omission. Generic claims such as “sustainable,” “eco-friendly,” “green,” “responsible,” “carbon neutral,” and “natural” pose enforcement risks. These claims need support from specific, current, and verifiable data. The CMA can now fine businesses directly up to GBP 300,000 or 10% of their global annual turnover for non-compliant claims.

How does UK environmental regulation differ from EU regulation after Brexit?

The UK kept most EU environmental laws after Brexit and has similar standards. Key differences include UK REACH, which requires separate registration for substances in Great Britain. The UK ETS works independently with its own cap and price. There is no equivalent to the CSRD in the UK, so large companies report under SECR and TCFD instead of ESRS. The UK published its own sustainability reporting standards (UK SRS) aligned with ISSB on February 25, 2026. They are voluntary for now, and the FCA has proposed mandating them for listed companies from January 1, 2027.

What happened to ASOS, Boohoo, and Asda after the CMA investigation?

On March 27, 2024, ASOS, Boohoo, and George at Asda signed formal undertakings with the CMA. The CMA made no finding of infringement, and no fines were imposed. The undertakings commit all three businesses to use accurate and specific green claims. They must publish transparent criteria for environmental product ranges and change how they display and promote their green credentials. The CMA can ask a court to enforce them if they are breached.