UK importer liability for supplier green claims
Yes. A UK importer can be responsible for misleading supplier claims it repeats, including by stocking labelled goods. Supplier assurances do not remove civil responsibility, even where the importer took reasonable precautions. Cambridge China Bridge can help gather factory evidence before you approve claims.
Stocking goods can mean repeating the claim
The CMA’s supply-chain guidance concerns claims reaching consumers, including through businesses upstream. It expressly says stocking a product may count as repeating its environmental claim. A factory printing the label does not automatically leave the UK seller outside responsibility.
Start with a claim inventory: photograph packaging, tags and inserts, then capture product listings and catalogue descriptions. Include supplier wording copied into your own sales material. This guide addresses responsibility; use our environmental-claims guide for the supporting evidence work.
Why a supplier assurance is not a civil defence
For CMA civil enforcement, an unintended or unwitting breach remains a breach. The guidance also says taking all reasonable precautions and exercising due diligence is not a defence in civil actions. A supplier’s signed assurance therefore does not, by itself, remove your civil responsibility.
Use declarations as part of your checking process. Ask what records support the exact wording and who holds them. Keep correspondence showing what you requested, what arrived and why you approved or refused the claim. Avoid treating a general promise that goods are environmentally friendly as approval for every label.
Approve wording against the actual goods
Build a claim file linking the proposed wording to the product, material, batch and supporting document. Ask whether the claim covers the whole item, a component or only its packaging. For the underlying checks, see our recycled and recyclable evidence guide.
Make claim approval a separate sign-off before printing. Record the approved artwork and evidence together, and compare the delivered packaging with that version. Our factory artwork approval guide helps organise the print approval process. Ask the factory to flag material or supplier changes before reusing approved wording.
If evidence is missing or the claim looks wrong
Put disputed stock and wording on hold while you investigate. Ask for evidence tied to the goods supplied, rather than another product’s certificate. If you cannot verify the claim, the CMA guidance says to consider wording you can verify; if the supplier cannot or will not verify it, consider the trading relationship for that product.
Changing your website alone leaves printed claims unresolved. Check labels, inserts, marketplace listings and material already sent to customers. Agree a correction plan with the supplier, retain the original wording and record the affected stock. Seek UK legal advice about goods already sold and the appropriate response.
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Keep checks even if the supplier is at fault
Responsibility and enforcement priority are different questions. The CMA considers which businesses to investigate; confirm with the CMA or a UK legal adviser how genuine compliance attempts may affect any penalties. Those considerations do not turn supplier assurances into a civil defence.
Assign someone to approve claims and someone to communicate changes to sales staff and customers. Keep a shared record of wording, evidence, approval and corrections. Cambridge China Bridge’s own staff in China can help request records and check factory packaging; keep the final claim approval with a named person in your business.
Frequently asked questions
Am I liable if the Chinese factory printed the claim?
You can be. The CMA says stocking a labelled product may count as repeating its claim. The factory’s role does not automatically remove the UK seller’s responsibility.
Does a supplier declaration protect me?
It can support your checking process, but it does not by itself remove civil responsibility. Reasonable precautions and due diligence are not a defence in civil actions under the CMA guidance.
Can I just remove the green claim from my website?
Check the goods too. Printed labels and inserts may still carry the disputed claim. Hold affected stock while you establish what needs correcting.
What should I ask the factory for before approving a claim?
Ask for the exact wording, its scope, supporting records linked to the goods supplied, and an explanation of any limitations. Keep those records with the approved artwork.