Introduction

To ensure that environmental claims by traders enable consumers to make more sustainable decisions, these claims must be reliable and specific. In the Netherlands, the Authority for Consumers and Markets (ACM, Autoriteit Consument en Markt), an independent regulator, has taken a strong stance against misleading and vague environmental claims, so-called greenwashing. In 2021, they published their influential Guidelines regarding Sustainability Claims, which were updated in 2023. Since then, they have confronted several companies with misleading environmental claims (i.e. Booking.com, Albert Heijn and Eneco). Part of the ACM’s 2025 Agenda is “promoting the use of honest and clear sustainability claims by businesses”. Because the ACM’s strong commitment to combating greenwashing matches well with green transition as one of ConsumerID’s focus points, we spoke with Joris Ruigewaard, senior enforcement official and coordinator sustainability at the ACM, about their approach to greenwashing. 

Interview

Why did the ACM decide to make greenwashing a key priority to address and publish guidelines regarding sustainability claims? 

Joris Ruigewaard: The ACM has a distinct mission: ensuring that markets work well for all people and businesses, now and in the future. As such, the ACM also looks towards the future. When talking about combating greenwashing, we first have to acknowledge the importance of sustainability in general. Climate change is one of the biggest challenges that society faces. Consumers and companies increasingly wish to contribute towards a world that remains livable in the long term. That is why consumers have become more interested in the sustainability impact of the products and services that they purchase. However, claims about sustainability are often seen as unreliable by consumers. By combating greenwashing, we help realise a level playing field for businesses and ensure that consumers are able to trust the sustainability information given by businesses. The guidelines were published in order the help companies phrase their sustainability claims and to prevent consumers from being misled.

This year, the ACM focuses on greenwashing in the food sector. Why was this sector chosen? Could you share an example of a recurring practice in this sector that is (potentially) misleading?

Joris Ruigewaard: The food sector was chosen because many unclear sustainability claims are still used in this sector. You can think of examples like ‘sustainable’ or ‘responsibly grown’, which may appear green, but explain little about the specific sustainability advantage of a product for people, animals, or the environment. Consumers really need more specific information in order to make an informed decision. In a recent letter to the sector, we call upon traders to check their sustainability claims and make adjustments where necessary.

What challenges does the ACM face when applying existing consumer laws to tackle greenwashing?

Joris Ruigewaard: A challenge when it comes to combating greenwashing is to strike a balance between, on the one hand, stimulating companies to engage with consumers regarding their sustainability endeavours, while on the other hand setting a high bar when it comes to the quality of that communication (honest and clear claims). We want to improve the sustainability claims that we see, but not be so demanding that companies forgo sustainability claims altogether. I’d like to think we are doing a good job at this, but this does require ongoing attention from our side. 

What do you see as the main added value of the Empowering Consumers Directive from the enforcement perspective? 

Joris Ruigewaard: The directive adds a number of important improvements when it comes to sustainability and consumer protection, from additional information obligations to blacklisting generic claims. Most importantly, the directive underscores the importance of sustainability for consumers and further anchors the role that enforcement agencies have when it comes to protecting consumers in this field. From a regulator’s perspective, it helps that certain generic claims, like climate neutrality, are now being banned for good. It saves us a lot of time in enforcing the use of these generic terms with such a clear legal prohibition.