Natalia Samodina, Interior Design Lawyer and our regular legal contributor, talks about the legal and commercial realities for UK furniture businesses around sustainability claims.
The urgency of climate disruption and resource depletion has shifted eco-consciousness from aspiration to imperative – one now embedded in law, boardrooms and consumer expectations.
For British furniture businesses, this means that environmentally-conscious – or “green” – claims, whether made in marketing materials, supplier communications or binding contracts, must meet rising standards of legal accountability under UK consumer law, international trade rules and environmental regulations.
This article explores the key domestic and European legislation around green claims and greenwashing applicable to the British furniture operators.
What are Green Claims?
Green claims are environmental representations made in product descriptions, advertising, packaging and supplier documentation. They suggest that a product, service or the business has a positive or reduced environmental impact.
In the furniture sector, they often relate to:
• materials: “FSC-certified oak,” “100% reclaimed teak,” “low-VOC finishes”;
• circularity: “zero landfill manufacturing,” “post-consumer waste frames”;
• carbon use: “carbon-neutral production,” “renewable energy manufacturing”; and
• chemicals: “OEKO-TEX® certified fabrics,” “no toxic dyes”.
To be compliant with the existing regulatory framework, these claims must be truthful, specific and substantiated to withstand scrutiny from regulators and commercial partners.
What is Greenwashing?
Greenwashing occurs when “green” claims misleading (including by silence or omission), exaggerated or unsubstantiated.
Examples include: vague terms like “eco-friendly,” selective disclosure (e.g. highlighting recycled packaging while omitting that the product is made from virgin tropical hardwood), misuse of certification logos and presenting future goals as current achievements (e.g. claiming “carbon neutral” status prematurely). Even visual cues, such as natural imagery or earthy branding, can mislead if not backed by verifiable environmental credentials.
All (and more) of such claims are banned as unfair commercial practices under the Digital Markets, Competition and Consumers Act 2024 (“DMCCA”).
DMCCA, in force since 6 April 2025, gives CMA direct powers to investigate and penalise misleading practices – including greenwashing – with fines of up to 10% of the offender’s global turnover.
Although CMA’s Sarah Cardell confirmed that the first twelve months of DMCCA’s new regime would be spent by CMA offering guidance and education, we are now over half way through that initial period, which expires on 6 April 2026 – and that’s when enforcement can begin in earnest.
Practical Tips
• avoid sweeping statements, e.g. implying product sustainability if only part of the product qualifies;
• be specific – general claims like “sustainable” or “green” need context;
• do NOT cherry-pick by highlighting one environmentally positive feature and omitting the full (and different) environmental impact;
• trust your instincts – if a claim feels hard to justify, rethink it.
EU Deforestation-Free Regulation 2023 (EUDR)
Despite some beliefs, deforestation is driven less by the timber trade and more by agricultural land conversion, which is legally permissible in many jurisdictions, even when it results in permanent forest loss. The EU Timber Regulation 2010 (“EUTR”), which focused solely on preventing illegally harvested timber from entering the EU market, proved insufficient to address this broader environmental impact.
To close this regulatory gap, EUTR was replaced with EUDR – a more expansive framework that requires businesses selling into the EU market to demonstrate not only the legality of timber sourcing but also that no deforestation or forest degradation occurred in relation to timber (with some exceptions, such as bamboo and rattan) and six other agricultural commodities (including rubber), regardless of local laws.
EUDR categorises market participants as “operators” (any person first placing relevant products in the EU) or “traders” (any person other than operator who makes products available in the EU). Operators’ obligations are stricter than traders’.
With compliance deadline fast approaching for medium-sized and larger businesses (30 December 2025) and the extended one for small- and micro-businesses (30 June 2026), UK furniture exporting operators would be under:
• a ban on placing on the EU market articles made of wood and rubber (with some exceptions), unless (i) those are “deforestation-free” and specifically for wood products that such have been harvested without “forest degradation” and (ii) they have been produced fully in accordance with the laws of the country of origin; and
• an obligation to submit a due diligence statement (“DDS”) via the EU’s central TRACES system BEFORE placing products on the market confirming (i) that the carried out due diligence has detected “no to negligible risk” of non-compliance, (ii) the geolocation data of the harvested plot; and (iii) risk mitigation measures (if required). Because the UK is a third country under EUDR, UK businesses must obtain an EU Economic Operator Registration and Identification (“EORI”) number, often through a representative or partner in the EU, to access TRACES and submit the DDS.
Although EUDR requirements do not obligate UK entities as non-EU players directly, the distinction is meaningless as the UK exporter’s European chain supply participants will be under EUDR obligations and will increasingly demand EUDR-compliant documentation to shield themselves from liability, often as a condition of sale or shipment.
GB Illegal Timber Regulation 2010 (UKTR)
For UK-only sales, UKTR (the UK version of EUTR) remains in force and compliance with UKTR is still required (although is sufficient). The risks of non-compliance are real.
In October 2017, Angora 2011 Limited (trading as Lombok) became the first UK furniture retailer convicted under UKTR. The company failed to exercise due diligence when importing an artisan sideboard from India and was fined £5,000 plus costs. The judge emphasised the importance of protecting biodiversity and public confidence in sustainable sourcing.
Exporters into the EU must meet both UKTR and EUDR standards, creating a dual compliance burden.
Conclusion
With regulations like the EUDR, UKTR and DMCCA reshaping the legal environmental landscape, British furniture businesses must treat environmental claims with the same rigour as financial or contractual representations.
The pressure isn’t just legal. Investors expect ESG alignment, consumers scrutinise sustainability narratives, and reputation hinges on environmental credibility. Whether refining product descriptions or preparing due diligence for EU markets, the priority is clarity, traceability and defensible claims.
And in a sector defined by material choices and design integrity, it’s also a commercial differentiator.
The content of this article does not constitute legal advice. If you would like tailored advice on the subjects covered in this article, please contact Natalia at natalia@interiordesignlawyer.co.uk.
