Context

British retailers are facing intensive regulatory change, potentially putting business reputation at risk.

ESG drivers:

Climate concern - the ‘Green agenda’ - e.g. EUDR

Product safety and risk management e.g. Product Regulation and Metrology Bill.

Engagement is imperative, but compliance can be complex.

Consequences of non-compliance

Products identified as non-compliant by the competent authorities face a range of consequences, including:

• Financial penalties on directors or hitting company accounts
• Products being refused placement on the market, writing off manufacturing, freight and promotional costs in addition to lost sales
• Costly product recalls
• Reputational damage with customers, suppliers and peers

Challenges

Demonstrating independence in risk auditing and reporting

Operational management

• In-house Technologists need to focus on New Product Development, critical compliance issues and value engineering. Information- gathering from suppliers is more efficiently outsourced

Visibility of compliance status

• Retailer data management systems present challenges identifying product risk profile. Need to be able to communicate risk simply to initial and external stakeholders
• Hard to push back to suppliers without quantifiable evidence of performance

How TRG can help

TRG’s market-leading technology platform is combined with in-house assessor and consultant expertise, all honed over nearly 20 years’ global client experience. We manage our clients’ risk in their supplier base, supply chains and product regulatory compliance, with our reporting solution providing clear and insightful data.

Supply chain regulatory compliance

Global supply chains are complex, demanding specialist skills and a robust technology base to ensure compliance through supplier training, documentation collection, risk assessment and risk mitigation to demonstrate due diligence to competent authorities (e.g. OPSS in the UK). Financial and product refusal/recall penalties apply in cases of non-compliance.

TRG provides UKTR due diligence to British retailers,  and for those placing in the EU including Northern Ireland, EUTR too. EUTR’s December 2025 replacement by the EU Deforestation Regulation (EUDR), brings cattle products, rubber, coffee, cocoa, oil palm and soy into scope. EUDR financial penalties for non-compliance are substantial, at up to 4% of annual turnover. 

TRG has upgraded its technology platform and assessment protocols for EUDR, and delivered a suite of virtual training sessions to EUDR clients’ suppliers, supported by video and written guidelines. First clients are live.

The UK Forest Risk Commodities Act (FRC) will cover cattle products, cocoa, palm oil and soy. Timber will remain under the UKTR, with the UK legislation focussing on illegal deforestation only. While implementation date is still to be confirmed, TRG is actively preparing for FRC. Please contact us for more information.

Product risk and compliance management

Evolving regulations present challenges for retailers. This requires awareness of how every new regulation or regulatory update is applied across myriad product types.  High on TRG’s radar are the following themes and updated regulations: 

• Claims verification
• UK Product Regulation and Metrology Bill
• Ecodesign for Sustainable Products Regulation
  • Including Digital Product Passports (DPP)
• Fire Safety of Domestic Upholstered Furniture Regulations
• EU Toy Safety Regulation

TRG builds and hosts compliance matrices, in consultation with clients, mapping client product types to relevant product compliance. An online Bill of Materials offers component-level data collection, documentary checks and reporting.

Product Technical File documentation is stored in our secure platform, with automatically triggered re-assessments to ensure evidence is up to date. A clear view of product compliance is provided to clients through reporting dashboards.

Green claims verification and anti-greenwashing

TRG’s certification claims service covers a wide range of standard claims for commodities such as recycled plastics, cotton, palm oil, cashmere, silk, leather and more.

British retailers selling into the EU will fall under the scope of regulations such as the EU Green Claims Directive, which aims to combat greenwashing by ensuring that environmental claims are clear, accurate and substantiated. Robust documentation and transparency will be needed, with substantial penalties for non-compliance. While details are still under discussion, businesses must prepare for stricter criteria and increased scrutiny. The UK Green Claims Code has similar objectives, and the CMA has stated that it could take enforcement action if guidance is not followed, though there is not currently a legal requirement.

CSRD (Corporate Sustainability Reporting Directive) and CSDD (Corporate Sustainability Due Diligence Directive)

The CSRD requires detailed sustainability reporting for large companies operating in the EU, covering ESG impacts. Similarly, the CSDD mandates businesses to identify, prevent, and address adverse environmental and human rights impacts across supply chains. UK-based businesses with operations or supply chains in the EU must comply. 

In the UK, The Sustainability Disclosure Requirements (UK SDR), serve as the closest equivalent to CSRD. While the UK has no direct equivalent to the CSDD, requirements of the UK Modern Slavery Act and the Voluntary Taskforce on Climate-Related Financial Disclosures (TCFD) show alignment with the broader regulatory trend.

In these evolving areas, regular, comprehensive and clear reporting is key.

Take the Next Step with TRG

TRG has experts to partner with you on your compliance journey, with TRG clients to date including John Lewis, Dunelm, DFS, Sainsbury’s, and The Home Depot.

Bookmark TRG website and LinkedIn or contact us directly on info@trackrecordglobal.com for detailed updates or advice.