CMA greenwashing enforcement: the fashion and FMCG cases
The CMA's flagship greenwashing action to date is its fashion-sector case: after investigating ASOS, Boohoo and George at Asda from July 2022, it accepted formal, legally binding undertakings from all three in March 2024 — no fine, no finding of infringement, but binding commitments to clean up their green claims. It has since extended its scrutiny to fast-moving consumer goods (household essentials such as cleaning and toiletry products) and, in 2026, published guidance on getting green claims right across the supply chain. This page sticks to what the CMA has itself published; only a court can decide whether any given claim actually breached the law.
The fashion case: ASOS, Boohoo and George at Asda
This is the case every UK business making green claims should know. The CMA opened an investigation into the environmental claims of ASOS, Boohoo and George at Asda in July 2022, after a sector review flagged possible greenwashing. In March 2024 it closed the investigation by accepting formal undertakings from all three retailers. Two points matter:
- It ended in undertakings, not a fine or an infringement finding. The CMA did not rule that the retailers had broken the law; instead they gave legally binding commitments about how they would make green claims in future. (The case also predates the CMA's direct-fining power under the DMCCA, which only started on 6 April 2025.)
- The commitments are a template for the whole market. The retailers agreed that green claims must be accurate and not misleading, with key information in plain, easy-to-read language; that statements about materials must be specific ("organic", "recycled") rather than vague ("eco", "responsible", "sustainable") without explanation; and that they would report to the CMA on compliance. The CMA issued an open letter urging the rest of the sector to follow suit.
General information, not legal advice. This guide summarises the CMA's published enforcement record. It is not legal advice, and only a court can decide whether a specific claim breaches the law. We describe outcomes the CMA has itself announced and do not attribute fines or findings it has not published.
The move into FMCG and household essentials
Having set a benchmark in fashion, the CMA widened its green-claims work into fast-moving consumer goods — the everyday "household essentials" category including cleaning products and toiletries. In flagging this work the CMA pointed to how pervasive environmental branding is in these aisles (it noted that the great majority of some categories, such as dishwashing and toilet products, were marketed as environmentally friendly), and to concerns about vague eco-statements with no evidence, misleading recycled-material and recyclability claims, and whole ranges branded "sustainable" without support.
Supply-chain guidance (2026)
The CMA has continued to build out its guidance. In 2026 it published "Making green claims: Getting it right, across the supply chain," which makes clear that responsibility for a green claim can extend beyond whoever first wrote it — a signal that businesses need to stand behind the environmental claims running through their supply chains, not just their own marketing lines.
What the record tells you to do
- Prefer specific, material-level terms ("organic", "recycled", "80% recycled aluminium") over blanket virtue-words — the exact swap the fashion undertakings required.
- Assume your whole range and supply chain are in scope, not just a hero product.
- Keep evidence accessible — the CMA's concern in FMCG was claims with "no evidence."
- Treat the fashion undertakings as the market benchmark — the CMA explicitly asked other sectors to align with them.
Frequently asked questions
What did the CMA do about greenwashing in fashion?
After investigating ASOS, Boohoo and George at Asda from July 2022, it accepted legally binding undertakings from all three in March 2024. The investigation closed without a finding of infringement; the retailers committed to accurate, clear green claims, specific material terms over vague ones, and compliance reporting.
Did the CMA fine the fashion retailers?
No. The case was resolved through undertakings, not fines, and it predated the CMA's direct-fining power (which began with the DMCCA on 6 April 2025). The undertakings are legally binding, and breaching them can itself lead to enforcement.
Is the CMA looking at other sectors?
Yes — it extended its green-claims work into fast-moving consumer goods (household essentials) and, in 2026, published guidance on green claims across the supply chain. We describe its published outcomes, not speculation.
Sources
- CMA case: ASOS, Boohoo and Asda greenwashing investigation — the case page and the March 2024 undertakings. gov.uk — ASOS, Boohoo and Asda greenwashing investigation
- CMA news: "Green claims: CMA secures landmark changes from ASOS, Boohoo and Asda" — the CMA's own announcement of the undertakings. gov.uk — Green claims: CMA secures landmark changes
- CMA: scrutiny of green claims in household essentials (FMCG) — the CMA's extension of its work into fast-moving consumer goods. gov.uk — CMA to scrutinise green claims in household essentials
- CMA guidance (2026): "Making green claims: Getting it right, across the supply chain". gov.uk — Making green claims across the supply chain
Content current as of 9 July 2026. The CMA's caseload evolves — re-check the CMA's own pages for the latest enforcement position before acting on anything time-sensitive.
Would your claims survive the same scrutiny?
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