Netherlands ACM: A Model for German Consumer Protection

The Dutch Autoriteit Consument & Markt (ACM) is an active consumer protection authority that addresses greenwashing and has published guidelines on sustainability claims.

ACM greenwashing guidelines: The ACM has set out general requirements under which environmental claims should be clear, substantiated and not misleading. A recurring point of review is whether generic environmental terms are used without a verifiable basis — that is, substantiated versus unsubstantiated sustainability claims (illustrative example: a blanket label such as “sustainable” without concrete indicators).

EmpCo context: Relevant to the EmpCo prohibition of blanket offset claims is the question of whether a claimed CO₂ offset can be fully substantiated. Claims without such evidence are a typical starting point for the greenwashing debate.

Significance for Germany: The greenwashing debate is increasingly shifting towards generic environmental claims in Germany as well. The relevant question is whether terms such as “sustainable” are backed by concrete, verifiable information.