What the DMCC Act Means for Environmental Claims and Greenwashing

The Digital Markets, Competition, and Consumers Act 2024 (DMCC Act) was introduced on April 6, 2025, bringing sweeping reforms to UK consumer protection law. It grants the Competition and Markets Authority (CMA) new powers to investigate and penalise misleading practices, particularly those involving greenwashing.

For businesses, the DMCC Act signals a new era of accountability in sustainability messaging. It empowers the CMA to act without court involvement and significantly increases the risks of making vague or misleading environmental claims.

Why environmental claims are under scrutiny

Environmental marketing claims are now one of the CMA’s key enforcement priorities. With the rise in consumer demand for sustainable products, businesses are under pressure to differentiate themselves. But with that comes the responsibility to ensure those claims are clear, accurate, and verifiable.

The DMCC Act introduces two critical shifts:

• Provisional Infringement Notices (PINs) can now be issued based solely on suspicion, posing reputational risk even without proof of wrongdoing.
• Substantial financial penalties can be enforced for breaches of consumer law, including misleading environmental messaging.

In short, detail matters more than ever. Broad or unsupported claims like "eco-friendly" or "green" are no longer acceptable unless they’re backed by rigorous, transparent data.

What powers does the CMA now have?

Under the Digital Markets, Competition, and Consumers Act, the CMA can:

• Initiate investigations based on reasonable suspicion, without a court order.
• Issue public PINs, warning businesses that their claims may breach consumer law, even before a formal investigation concludes.
• Enforce operational changes, such as requiring updates to staff training or removal of misleading claims.
• Impose financial penalties based on global turnover and the severity of the breach.

Examples of potential fines:

Note: Penalties are based on whichever is higher—fixed amount or percentage of global turnover.

Examples of claims at high risk of greenwashing

Here are common types of claims now considered non-compliant under the DMCC Act:

• Vague terminology: Words like “eco-friendly” without context or evidence.
• Misleading comparisons: Saying “better for the planet” without defining what it’s being compared to or based on what data.
• Claims based on minimal or selective improvements, such as “lower carbon” recipes or new packaging that aren’t supported by full life cycle analysis
• Selective disclosures: Highlighting positive attributes (e.g. sustainable materials) while ignoring other high-impact areas like packaging or transportation.
• Unverifiable certifications: Using self-created badges or logos that are not independently accredited.
• Offset-only strategies: Claiming "carbon neutral" purely through offsets, with no emissions reduction effort.
• Lack of timeframes or goals: Statements like “on the path to net zero” without defining milestones, scope, or measurable targets.

These kinds of claims not only erode consumer trust but now carry legal risk.

Making clear, compliant green claims

The DMCC Act demands a higher standard for environmental marketing and businesses must respond with a more diligent, transparent approach to sustainability claims. Greenwashing risks can now carry serious financial and reputational consequences, but they can be avoided by taking the right steps.

To build trust and stay ahead of regulation, businesses should:

• Substantiate every claim: Use robust, verifiable data—ideally from full life cycle assessments (LCAs) or product carbon footprints (PCFs)—to support your messaging.
• Communicate clearly: Avoid vague or sweeping terms like “green” or “eco-friendly.” Be specific about what aspect of a product is sustainable, and clarify scope, timeframe, and comparison where applicable.
• Include qualifiers where needed: If a claim only applies to a specific component or phase of a product’s life cycle, make that clear.
• Use credible third-party certifications: Avoid self-created labels. Where appropriate, rely on independently verified certifications to reinforce the credibility of your claims.
• Align with the Green Claims Code: The CMA’s Green Claims Code outlines six key principles for making fair, honest, and substantiated environmental claims. Use it as a compliance baseline.

By embedding these principles into your sustainability messaging, you not only reduce risk, but also build stronger, more credible relationships with customers, investors, and regulators.

How Zevero helps comply with the DMCC Act

Zevero helps businesses move from intention to impact with tools and expert guidance ensuring that your sustainability claims are compliant, credible, and backed by data.

Transparent, Auditable Data

Our platform makes it easy to calculate and track emissions across your products and operations. Every data point is audit-ready, providing the level of transparency needed to meet CMA scrutiny.

• Track product carbon footprints (PCFs)
• Generate emissions reports for customers, investors, and regulators
• Maintain historical data for assurance and verification

Strategy and decarbonisation built in

• Identify where your claims may carry risk or require more evidence
• Build a credible decarbonisation roadmap to support reduction-first strategies
• Set and validate emissions reduction targets 

The DMCC Act raises the bar for environmental claims. Zevero helps you meet it.

Get in touch today to future-proof your sustainability strategy and stay compliant under the Digital Markets, Competition, and Consumers Act.