What tougher evidence means for promotional products

What to take away

Why has merchandise procurement changed?

The Digital Markets, Competition and Consumers Act 2024 gave the Competition and Markets Authority the power to decide for itself whether a commercial practice is unfair. It can act without going to court.

The consumer protection provisions took effect on 6 April 2025. The CMA can fine a business up to 10 per cent of global turnover or £300,000, whichever is higher, for a misleading claim.

For merchandise buyers this matters because branded items are a marketing channel. A tote bag described as recycled when it is not, or a bottle labelled carbon neutral without a published method, sits inside the misleading actions rules.

The second shift is environmental reporting. The Climate Change Act 2008 provides the statutory framework for UK emissions targets, but it does not itself require each merchandise supplier to provide product-level material or emissions records. Buyers increasingly request such information through procurement and claim-substantiation checks.

Suppliers who cannot produce a material breakdown, a weight per unit and a disposal route are being removed from tender lists.

A third change is technical. Import classification is no longer a customs clerk's problem. Buyers sourcing directly from overseas need the commodity code before they can quote a landed cost. GOV.UK's guidance on finding commodity codes for imports into or exports out of the UK is the starting point for that work.

The code also sets duty rates and whether extra checks apply. Quote a landed cost on the wrong code and your budget forecast is wrong.

The practical effect is that supplier questions move earlier. Expect queries about material and origin at the artwork approval stage, not at invoice.

Evidence gathering takes longer than most buyers expect. Material composition and origin data often sit with a factory rather than a UK account manager, so a request made in March may not come back until April.

Tender documents now ask for this before pricing. A supplier who leaves the sustainability section blank is usually marked down rather than rejected, which still costs them the work.

What changes in 2027

The UK carbon border adjustment mechanism begins on 1 January 2027. HMRC will administer the mechanism, and importers of goods within its scope will need to report embodied emissions through CBAM returns. It covers specified commodity codes in sectors including glass and ceramics, not automatically every drinkware line. Check HMRC's registration and reporting requirements, and use GOV.UK commodity-code guidance to confirm whether an item is in scope.

In England, Simpler Recycling duties reach businesses with fewer than ten employees by 31 March 2027. Disposal and waste questions will sit in the standard merchandise questionnaire.

What should a merchandise platform actually do?

Start with the job, not the software. A platform earns its place if it removes manual work from four tasks: catalogue management, approval routing, stock visibility and reporting.

Catalogue management is where most implementations fail. If the platform cannot hold variant-level data such as material, weight, decoration method and country of origin, you will rebuild the same spreadsheet every quarter.

Build a field list before you shortlist. At minimum you need material, weight, decoration method, country of origin and a disposal note. If a vendor calls those fields custom, that tells you how their data model was built.

Approval routing matters when more than one brand or region buys. A merchandiser in Manchester should not be able to order an item that breaks a brand rule set in London.

Roles and permissions deserve a slot in the demo. Ask how a regional manager's view differs from a head office buyer's, and how you would stop a leaver from ordering.

Stock visibility is the commercial case. Teams that can see what is already held avoid reordering. Worked example, not a benchmark: a mid-sized employer spends £60,000 a year on branded items, and holding 15 per cent less buffer stock frees up about £9,000.

Warehouse stock and catalogue stock are not the same thing. Ask whether the platform shows what a supplier holds or what you already own.

Reporting is the part finance signs off. If the platform cannot export spend by department, cost centre and campaign, someone will do it by hand.

Decoration data is what makes a reorder quick. If the platform remembers the print position, ink reference and supplier, a repeat order becomes a two-click job.

Ask to see a live catalogue rather than a demo environment. A general ecommerce platform such as Shopify can host a self-serve company shop, but it is not a substitute for supplier-level sourcing, decoration or product-evidence records. If you want to see what is on the market before you write requirements, this overview of promotional merchandise tools in England is a reasonable first pass.

Which providers fit which buying model?

The market splits into four types, and most teams end up buying from two of them. Named distributor examples include EverythingBranded, Total Merchandise and 4imprint; managed merchandise agencies buyers can assess include Brand Addition and Fluid Branding. For branded workwear and embroidery, Workwear Express is a specialist supplier to include when decoration capacity matters. The British Promotional Merchandise Association (bpma) publishes a member directory you can search by product type.

Pricing models vary widely, so compare on total cost per item delivered rather than headline unit price. Ask each provider for a worked example using your own volumes and your own decoration mix.

Watch for decoration capacity. A provider that outsources embroidery adds a link to the chain and a delay to every reorder.

Lead times and minimum order quantities decide whether a provider suits you at all. A supplier with a 500-unit minimum, for example, is no use to a team that needs 40 items with a logo.

Before a formal tender, check the supplier's identity, who handles each production and decoration step, product-level material and origin evidence, sample approval, lead times, minimum order quantities, stock ownership, references and how defects are handled. Use these checks alongside promotional merchandise vendor due diligence to assess whether a supplier can substantiate its claims.

Consolidation is the quieter saving. Two suppliers mean two invoices and two delivery costs. Pooling similar lines under one provider often cuts administration more than it cuts unit price.

Ask for two references and use them. A reference call with a buyer of similar size surfaces service problems that no proposal document will mention.

How do you choose between promotional merchandise software?

Write the requirements before you see a demo. A short list of ten must-haves beats a feature matrix with two hundred rows.

Then test the data. Ask each vendor to load ten of your real products, including one with a complex decoration and one with a compliance restriction. Watch how long it takes and what breaks.

Check the integration story. Your platform should push spend data into your finance system and pull recipient data from your CRM or HR system. Manual exports are a warning sign.

Score every vendor on the same sheet, and take a reference call with a customer of a similar size.

Look at the commercial model closely. Per-item fees, transaction fees, artwork charges and setup costs all land somewhere. Ask for a three-year cost, not a first-year cost.

Migration is the hidden cost. If your product data lives in spreadsheets owned by three people, budget time to clean it before anyone loads it into a platform.

Implementation fees are the line most often missed in the budget. Ask what onboarding includes and what becomes a chargeable change request later.

Finally, ask about exit. If you leave, do you get your catalogue, your artwork files and your order history in a usable format? A vendor who hesitates on that question is telling you something.

Score vendors on data coverage, approval workflows, integrations, access controls, onboarding, support, data portability and the full commercial terms. Record the evidence behind each score, rather than relying on the vendor's description. A structured approach to promotional merchandise software selection covers scoring, reference checks and contract clauses in more detail.

How should campaign data connect to merchandise?

Give each merchandise order a campaign identifier and agree how its source, quantity, recipients and outcome will be recorded. That lets buyers connect product evidence and spend to campaign results without treating media metrics as merchandise evidence.

If merchandise supports a paid campaign, keep paid responses distinct from redemptions. The LinkedIn Ads self-serve platform reports LinkedIn advertising activity, not stock, supplier claims or merchandise performance.

Agree naming conventions across the merchandise order, finance record and CRM before launch. Reconcile them after the campaign so an enquiry or redemption is not attributed to the wrong activity.

For a campaign with multiple channels, compare merchandise with the alternative the team would otherwise have funded, using the same audience and time window where possible. Keep the method and any limitations in the evidence file.

What does compliance look like in practice?

Compliance is not a policy document. It is a set of questions asked before every order.

Compliance starts with three questions. What is the item made of, and can the supplier evidence it? Where was it made, and under which commodity code? How is it disposed of once the recipient has finished with it?

On claims, the standard is simple. The CMA's Green Claims Code is official guidance for environmental claims: statements must be accurate, clear and substantiated, with evidence held to support them.

The Climate Change Act 2008 provides the statutory framework for UK emissions reduction targets. Any marketing claim about carbon performance needs a defensible method behind it.

Some categories carry extra duties. Toys, electricals and children's items attract safety requirements, and the supplier should hold the test documentation for the UK market.

Examples of evidence schemes include the Global Recycled Standard (GRS), which can support recycled-content claims when the product and certificate are in scope, and Forest Stewardship Council (FSC) chain-of-custody certification for eligible paper or wood products. ISO 14001 certifies an organisation's environmental management system, not a product's environmental impact. Sedex is a membership and data-sharing platform, not a product certification; EcoVadis provides company-level sustainability ratings, not proof of a particular item's material. Check the certificate holder, product scope, validity and chain of custody.

If a claim cannot be substantiated, change the claim. Removing a vague phrase from a product page is cheaper than defending it.

Keep the evidence file with the order, not in a separate sustainability folder.

How do you measure whether merchandise works?

Set the measure before the order. Common options include redemption rate on a code, response rate to a follow-up message, and cost per qualified conversation.

Worked example, not a benchmark: a team spends £25,000 on 5,000 items and prints a unique code on each. If 400 codes are redeemed, that is an 8 per cent redemption rate and £62.50 per redemption.

Recall and perception measures sit alongside hard metrics. A short survey at an event can tell you whether recipients remembered the brand, though it will not prove a sale.

A control group is the cleanest comparison. Hold back a similar audience and give them nothing, then compare enquiry rates over the same period.

Cost per item is not a result. It tells you what you spent, not what changed. Pair it with a response measure or the board will read it as decoration, not marketing.

Compare against the channel you would otherwise have used. If an alternative produces a lower cost per qualified conversation, that is useful information, not a failure.

Segment recipients by role, location, campaign objective and likely use for the item, then choose a relevant action to measure, such as redemption, follow-up response or qualified conversations. Avoid treating a broad audience average as proof that every group valued the item. This audience research for promotional merchandise explains how to segment recipients so the measurement means something.

What does implementation look like week by week?

Implementation is where most programmes lose momentum. A phased plan keeps it moving.

Weeks one and two: agree the catalogue scope and the approval rules. Weeks three and four: load data and test the integrations. Weeks five and six: run a pilot with one department. Weeks seven onward: roll out and review monthly.

The pilot matters. It surfaces the exceptions, such as an item that needs a different decoration method or a department with an unusual cost centre structure.

Change management decides whether people use the platform. Name a champion in each department and give them a route to raise problems.

Book training after the pilot, not before. Users who have already placed one order ask better questions and remember the answers.

Plan the transition for existing stock. Running two catalogues in parallel for a quarter is normal, and it avoids write-offs.

Before roll-out, export and clean existing product data, assign an owner to each data field, and test sample orders and integrations in the pilot. Document who handles support and how catalogue, artwork and order-history data can be handed over. A detailed walkthrough of promotional merchandise tool implementation covers data migration, user training and the handover to business-as-usual support.

Common questions

Do I need a platform, or can I just use a good distributor?

A distributor is usually enough if you buy fewer than about a dozen lines a year and one budget holder signs everything off. Once you have multiple departments, brand rules or reporting duties, a platform earns its cost by removing manual administration.

How long should a supplier contract run?

Twelve months is common for a first term, with a break clause at six. Longer terms are fine when pricing is fixed and service levels are written into the agreement with remedies attached.

What evidence should I ask a supplier for?

Ask for material composition, country of origin, the commodity code used for import, decoration method and any certification held. If a supplier cannot produce these on request, treat that as a gap rather than a delay.

Can I make environmental claims about branded merchandise?

Yes, if the claim is accurate, specific and substantiated. Avoid vague terms such as eco-friendly. State the material, the recycled content and the evidence behind it, and keep that evidence with the order record.