The CMA’s latest guidance makes clear that ATFs, dismantlers and green parts suppliers are jointly liable for environmental claims they make or repeat. From April 2025, misleading “green” messaging can trigger direct CMA fines. Operators need robust evidence, approval processes and wording, turning genuine performance into compliant, defensible commercial advantage.
UK consumers are increasingly looking for products and services that genuinely cut environmental impact, and that includes how vehicles are repaired, recycled and scrapped. From “green parts” and “carbon neutral recycling” to “zero waste depollution,” environmental messaging is now part of many ATFs’ sales stories. The Competition and Markets Authority (CMA) has made it clear that these claims must be accurate, evidenced and honest, and that everyone in the supply chain, not just the brand on the box, shares responsibility.
This latest CMA guidance builds on the Green Claims Code and explains how liability works across complex supply chains. For vehicle recyclers, dismantlers and green parts suppliers, it’s a reminder that you can benefit commercially from your environmental performance, but only if your claims stand up to scrutiny.
Green claims: more than just slogans
The CMA defines “making” an environmental claim very broadly. It covers:
- What you say on your website, adverts, catalogues and portals
- Labels and statements on parts, packaging and paperwork
- Logos, imagery and “green” branding that suggest environmental benefits
- What you don’t say, for example, leaving out key information about how to dispose of a product or when a benefit actually applies
If a dismantler promotes a part as “100% recycled”, “zero waste”, or “fully recyclable” when the reality is more complex, that’s a risk. And if you repeat a manufacturer’s or marketplace’s claim, for exampl,e by listing a component as “carbon neutral” or “sustainably sourced”, you may be treated as having made the claim yourself.
Shared liability along the supply chain
The guidance is clear: every business in the chain must take responsibility for the green claims it makes or repeats.
- Retailers and platforms (for this sector, bodyshops, insurers and online marketplaces) must not blindly pass on claims from suppliers if they look exaggerated or unclear.
- Brands and manufacturers must hold solid, up-to-date evidence and make it available so others can verify claims.
- Suppliers and dismantlers need systems to track provenance, composition, testing and recycling performance, and update partners if things change.
If you can’t get the information you need to be confident a claim is accurate, the CMA’s message is simple: change the wording, or don’t make the claim.
DMCC Act: tougher tools, higher stakes
From April 2025, the Digital Markets, Competition and Consumers Act (DMCC) gives the CMA much sharper teeth. The authority can now:
- Decide whether consumer law has been breached
- Order businesses to change their conduct and provide redress
- Impose significant fines directly, without going through the courts
Importantly, the CMA doesn’t have to prove you meant to mislead. An “innocent” or unwitting misleading claim is still a breach of consumer law, and “we trusted the supplier” is not a defence. Intent and genuine efforts to comply may reduce penalties, but they won’t erase liability.
The CMA says it will prioritise the most harmful and “egregious” practices, including cases where:
- Businesses should already know their obligations (for example, where guidance like the Green Claims Code exists)
- Internal processes for checking and approving claims are weak or non-existent
- Misleading claims are being made at scale across a brand, range or platform
What this means in practice for ATFs and vehicle recyclers
For ATFs, dismantlers and green parts suppliers, the direction of travel is clear: if you’re promoting environmental benefits, you need the paperwork and processes to back them up.
Practical steps include:
- Put a formal green-claims process in place – who can approve claims, what evidence is needed, how often it’s reviewed.
- Demand evidence from upstream suppliers – certificates, test reports, traceability data or written declarations that claims are accurate and up to date.
- Review claims regularly – especially when you change suppliers, materials or processes, or when regulations and standards move on.
- Be specific and transparent – “this panel is reused OEM”, “this part comes from a VRA Certified supplier”, “this process diverts X% from landfill”, rather than vague “eco-friendly” or “sustainable” badges.
- Explain conditions clearly – for example, where a part is “recyclable” only through certain routes, or a claimed saving depends on particular repair choices.
A compliance duty – and a commercial opportunity
The CMA is not trying to stop businesses from talking about environmental performance. In fact, it recognises that credible green claims reward genuine investment and help consumers choose better options, which is exactly where professional ATFs should be strongest.
For UK vehicle recyclers, this guidance is a prompt to tighten up how green claims are created, checked and shared with partners. Those who can provide robust, traceable evidence and clear, honest messaging will be better placed to win work from insurers, bodyshops and OEMs under growing ESG pressure, while avoiding the reputational and damage of being accused of greenwashing.
Source: www.gov.uk/government
Further reading on ATF Professional
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Green Parts on the Up: What the 2025 State of the Industry Report Means for UK ATFs
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Car industry settles competition law case in relation to vehicle recycling
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House of Lords presses Defra for timelines and tougher action on ‘low-risk, high-reward’ waste crime
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Digital Waste Tracking: Mandatory reporting now set for October 2027
