From 27 September, Dutch sustainability claims must connect sales language to current evidence.
A small webshop owner reviews a new product page on Friday afternoon. The supplier calls the product sustainable. The designer adds a green badge. The agency writes “environmentally friendly” beside the order button. Everyone has completed a reasonable task, yet nobody has asked what the words mean, where the evidence sits, or whether the badge may be used at all.
That question becomes more urgent on 27 September 2026. From that date, stricter Dutch rules apply to consumer-facing sustainability claims. The Dutch Authority for Consumers and Markets, ACM, has warned businesses to review their wording, labels and product information. Broad claims such as “green”, “environmentally friendly” and “ecological” face particularly strict conditions.
Misleading sustainability claims were already prohibited. ACM acted in August after cruise seller Captain Cruise used broad claims including “sustainable cruising” and “environmentally friendly trip” without substantiation. The company changed or removed text and visual material. The September rules make several boundaries clearer and tighter. They also bring the governance question closer to the sales desk.
The claim belongs to the business
Marketing language often enters a company through the side door. A manufacturer supplies a description. A marketplace imports product data. A designer creates an attractive symbol. Customer service repeats what appears on the website. By the time management sees the claim, it may already be printed on packaging and copied across several channels.
A public claim is a responsibility test for the whole business. A company cannot treat it as the private work of its web agency. The seller needs to understand what is being said to the consumer and what supports it. Text and visual presentation are assessed together, so a leaf, colour scheme or badge can shape the same impression as the words beside it.
The distinctions matter. A product claim is not the same as a statement about the whole company. A comparison needs a clear baseline. A future environmental target needs measurable aims and a concrete plan. A label needs an acceptable scheme, including independent control. ACM says company-owned sustainability labels without independent control are no longer permitted.
Good intentions do not bridge these differences. Neither does a supplier’s general assurance. The supporting information must fit the actual product, claim and sales channel. It must also remain current. That is where a simple sentence on a product page starts touching procurement, contracts, stock records and management responsibility.
Evidence must travel through the company
Imagine that the webshop owner asks the supplier for support. A certificate arrives, but it concerns the manufacturer rather than the product. An environmental study covers last year’s materials, while the current batch uses a different component. The badge was created internally and has no independent scheme behind it. The claim travelled faster than its evidence.
A small company does not need to build a compliance department around every adjective. It does need a reliable route from the public statement to its source. Someone should know the exact wording, the product concerned, the evidence date, the assumptions behind any comparison, the channels carrying the claim and the person who approved it.
A modest claim register can serve that purpose. It is not a statutory form. It is a practical governance method. The owner can see whether the same claim appears on a website, package, marketplace listing, brochure and social post. The register also creates a review point when suppliers, specifications or standards change.
The framework reaches further than familiar green language. ACM also points to consumer information about durability, repairability, software updates, spare parts, guarantees and the effects of non-original parts. Comparison services must be more transparent about how environmental and social features are assessed. For sellers of electronics and white goods, product data can connect directly to customer-service promises.
Old packaging carries a cash question
The owner then walks into the warehouse. Two pallets still carry the company’s own green badge. Another slow-selling line uses packaging printed eighteen months ago. That stock turns a communication problem into a cash decision.
ACM recognises that older inventory may carry claims or labels that do not meet the stricter rules. In some cases, stock could require withdrawal or destruction. Supervisors may consider specific transition problems where a business can demonstrate genuine old stock and timely efforts to comply. That is case-specific consideration, not a general right to sell everything through.
Ordinary records now become valuable. Batch dates, quantities, invoices, retailer correspondence and relabelling decisions can show what existed and when the business started correcting it. Contracts also matter. If packaging came from a supplier or products sit with a distributor, someone will bear the cost of replacement, delayed sales, credit notes or returns.
Thin margins make timing important. Reviewing a claim before the next packaging run is usually less disruptive than repairing it across shops, platforms and warehouses later. The same applies to a product launch. Evidence gathered during procurement is cheaper and more useful than evidence chased after advertising has gone live.
Trust needs an owner
The practical starting point is a calm look across consumer-facing channels. Review environmental words, badges, images, filters, comparisons, guarantees, repair statements and future promises. The useful management question is simple: who can explain this claim today, using information that still matches what we sell?
Our webshop owner may decide to remove one badge, narrow another claim and ask the supplier for better product data. She may relabel the two pallets and give one person authority to approve future sustainability wording. These are small adjustments, but together they stop public statements from floating free of the business behind them.
Sustainability communication should not become timid or empty. Businesses making genuine improvements should be able to describe them clearly. The stronger discipline is precision: say what changed, compared with what, for which product, and on what basis.
A green claim can still help a customer choose. From 27 September, it must also show that the company making the claim knows what it is promising.
If your business needs to review its sustainability claims, labels and supporting evidence before the new rules apply, contact us for practical counsel.
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- Vanaf 27 september 2026 strengere eisen aan duurzaamheidsclaims | ACM
- Wettenbank - Legal trigger and date of application
- Autoriteit Consument & Markt - Claims must be specific, supportable and current
- Autoriteit Consument & Markt - Existing enforcement already targets unsupported claims
- Autoriteit Consument & Markt - Old stock, packaging and transition evidence
- Autoriteit Consument & Markt - Supervisory direction: consumer information, repair and supply-chain pressure
- Ondernemersplein - Practical baseline for comparisons, future targets and labels
- Overheid.nl
