The amended Unfair Commercial Practices Directive (introduced via Directive 2024/825) entered into force in the EU in 2024. Member state transposition deadlines run through 2026, with enforcement following in sequence, and penalties reach 4 per cent of annual turnover in the relevant member state. Equivalent and parallel regulatory architecture is in force or emerging across the United Kingdom (DMCC Act, FCA anti-greenwashing rule, CMA Green Claims Code), the United States (FTC Green Guides revision, NY AG enforcement, California disclosure laws), and other major jurisdictions.
The Green Claims Directive is expected to add further substantiation and verification requirements on top. CSDDD introduces continuous supply chain due diligence obligations that extend beyond the claim itself to the underlying value chain.
Organisations that wait for clarity will be governing claims retrospectively against enforcement that has already begun. Organisations that act now are building the governance architecture that will be defensible across the next three regulatory cycles.