The DMCC Cheat Sheet: What Food Businesses Need to Know

The Digital Markets, Competition and Consumers Act (DMCC) is a major piece of UK consumer law that came into force in April 2025, giving the Competition and Markets Authority (CMA), the country’s competition and consumer protection regulator, new powers to publicly intervene in cases of potentially misleading environmental claims.

For food businesses, this introduces significantly higher expectations around clarity, evidence, and internal governance. The CMA can now issue Provisional Infringement Notices (PINs) — formal public warnings issued without court approval, based on suspicion alone. This means reputational damage can occur even in the absence of a formal penalty.

Claims tied to packaging, sourcing, or product reformulation — especially those using terms like “eco-friendly” or “100% plant-based” — will be more closely scrutinised. These are often referred to as ‘green claims’ — statements that suggest a product or business is environmentally friendly, low-impact, or sustainable.

The CMA has already signalled its focus on high-impact sectors such as food and retail.

With penalties of up to 10% of global turnover and new due diligence requirements, businesses must ensure their claims — and the processes behind them — can withstand external scrutiny.

Here’s a quick factsheet of everything food businesses need to know:

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The DMCC - Cheat Sheet 

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Effective from:

• 6 April 2025 — with no formal grace period, meaning the rules apply immediately.

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Who’s affected:

• All UK businesses making marketing or environmental claims (B2C or B2B)
• Applies to advertising, packaging, web copy, product labels, social posts, customer emails

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Key enforcement features:

The CMA no longer needs to go to court to take action. Instead, it can:

• Launch an investigation based on reasonable suspicion alone
• Issue Provisional Infringement Notices (PINs) that are made public — even if the business is later cleared. These are formal notices from the CMA that warn a business may be in breach of consumer law and outline what needs to change.‍
• Impose financial penalties based on turnover, reputational harm, intent, and scale of breach‍
• Demand operational changes, such as staff training, policy updates, and removal of claims

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Potential fines — based on global turnover:

• £30,000 or 1% — for providing false information to the CMA
• £150,000 or 5% — for breaching undertakings (e.g. failing to comply with CMA directions)
• £300,000 or 10% — for final infringement notices issued after formal investigation

These penalties are fixed maximums set out in legislation and are applied based on whichever is higher: the fixed amount or the percentage of global turnover.

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Focus areas for food businesses:

• Bold or comparative green claims (e.g. “better for the planet”)
• Incomplete life cycle claims (e.g. covering farming but omitting packaging/transport)
• Use of terms like “eco-friendly,” “biodegradable,” or “100% plant-based”
• Reformulated recipes, packaging claims, or “lower carbon” positioning based on selective improvements — without supporting full life cycle data.

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Best practices now expected:

To avoid risk, the CMA expects food businesses to follow clear internal processes and ensure every claim is backed by data.

• Full Life Cycle Assessments (LCAs)
• Internal evidence files and sign-off from legal/sustainability teams
• Portfolio-level consistency (not just product-level claims)
• Staff training and regular marketing reviews

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Other rules still in effect:

These rules build on earlier guidance — they don’t replace it.

• CMA Green Claims Code
• ASA guidance on environmental claims
• Future EU Green Claims Directive (2026) — relevant for food exporters

The pressure to comply is only increasing — but so are the tools to help.

Want to learn more? Our full guide on the DMCC and the Green Claims Code is coming soon.