Week 38 ·
Week 38: EmpCo countdown, Finland's repair duty, and the data on green claims
The pressure moved off the adjective and onto the object. Almost everything that moved in the last ten days governs a physical property of the product or what happens to it after purchase – whether it can be repaired, what chemistry sits inside it, whether the shop must take the packaging back, whether it may be destroyed at all. Even the two Swedish advertising rulings turned on a physical fact rather than a word: a hen kept indoors, a parmesan set with calf rennet. And the first panel evidence from the EmpCo transposition suggests brands are not going quiet – they are rewriting claims so the object can carry them.
Regulation & policy
Finland · Right to repairGuidance issued 7 September 2026 · law in force since 31 July 2026
Finland tells manufacturers they must repair what the warranty no longer covers
Finland's competition and consumer authority KKV published consumer guidance on Act 573/2026, which amended chapters 5 and 8 of the Consumer Protection Act (38/1978) and has been in force since 31 July 2026, transposing Directive (EU) 2024/1799. Manufacturers of washing machines, tumble dryers, dishwashers, refrigeration appliances, vacuum cleaners, electronic displays, mobile phones and tablets must now repair a product even where the consumer has no right to a free repair, including normal wear and damage the consumer caused themselves, against a reasonable fee, and may refuse only where repair is impossible.
The scope tracks the Ecodesign Regulation's repairability requirements. The law also introduces the voluntary European repair information form, which lets a repairer set out the essential conditions and price of a repair before a contract is made.
The effect is to move durability from a claim a brand makes about itself to a floor every manufacturer in the category stands on.
Sources: KKV (7 Sep 2026) · Directive (EU) 2024/1799
Sweden · ChemicalsInvestigation opened 11 September 2026
Sweden's chemicals regulator turns its attention to the heat pump
Kemikalieinspektionen opened a national investigation into reducing TFA emissions from fluorinated refrigerants – the gases used in heat pumps, refrigeration and freezing systems, building air conditioning and vehicle air conditioning. F-gases account for more than 50% of Swedish TFA emissions, and TFA has been found in groundwater at over 90% of tested sites in Sweden. The EU's Risk Assessment Committee has recommended classifying TFA as environmentally hazardous, persistent, mobile and toxic for reproduction.
Four workstreams run this autumn: where the largest emissions originate, substitute substances and technologies, how leakage during use, service and disposal can be minimised, and which national policy instruments could reduce F-gas emissions. The agency will also re-examine approvals for plant protection products capable of forming TFA.
It places a chemical question inside a product category that consumers buy specifically as an environmental choice.
Sources: Kemikalieinspektionen (11 Sep 2026)
EU · CircularityConsultation opened 10 September 2026 · closes 4 November 2026
The Commission asks whether VAT should make destroying goods expensive
DG TAXUD opened an eight-week public consultation on adapting VAT rules to circular business models. It runs on three named strands: the treatment of second-hand goods, the destruction of viable goods, and VAT deduction on passenger cars used for business purposes. The consultation feeds the upcoming Circular Economy Act; the evaluation and impact assessment are expected to conclude in early 2027 before any proposal to amend the VAT Directive.
ESPR already prohibits destroying unsold clothing and footwear. This is the first sign that the tax system may be asked to price the same behaviour across every other category.
Netherlands · Packaging · UpdateFigures published 10 September 2026
The Dutch deposit expansion now has a take-back date – and a €129m gap behind it
This is an update to the Dutch cabinet's deposit proposal reported in week 37. Consumentenbond has published the figures underneath it. Shops and other drinks sellers would face a mandatory take-back duty (innameplicht) from 1 January 2028.
Return rates in 2025 were 78% for plastic drink bottles and 86% for cans, against a 90% statutory collection target. €506 million in deposits went unclaimed between 2021 and 2024, and €129 million in 2025 alone. Germany exceeds 95%, while Lithuania and Slovakia passed 90% within a few years of starting. Consumentenbond argues points of sale should in principle take packaging back and refund the deposit, rather than routing consumers to separate machines.
An unclaimed deposit records a consumer who paid into a system they did not or could not use – which makes convenience, rather than packaging design, the variable under scrutiny.
Sources: Consumentenbond (10 Sep 2026)
Consumer & brand
Sweden · AdvertisingTwo decisions handed down 2 September 2026
Two Swedish advertising complaints upheld in one day, both over a picture the product could not support
MAX Burgers was found in breach of ICC Article 5 over its "VEG Lakto-ovo" Crispy Supreme Parmesan, whose parmesan is set with animal rennet taken from calf stomachs. Reklamombudsmannen expressly rejected the argument that a complete ingredient list on the company's website cured the advertisement, holding that each marketing unit is assessed on its own and that later corrective action does not save it.
The same day, Landsberga Gård Maskin was upheld over a store sign selling "Närvärpta Gårdsägg från utehönorna" beside a hen saying it likes to "sprätta, sandbada och picka mask i solen". The eggs were stamped code 2, indoor-reared, following avian-flu housing orders in Uppsala County, and the farm conceded it had never produced a winter version of the sign.
Both decisions turned on a physical fact inside the product rather than on the wording of a claim, and in both the correct information existed elsewhere. EmpCo, which applies from 27 September, removes that as a defence.
Sources: RO decision 2603-38, MAX Burgers (2 Sep 2026) · RO decision 2605-68, Landsberga Gård (2 Sep 2026)
Research · Green claimsPublished 3 September 2026
First panel evidence suggests brands are not going quiet – they are getting specific
A 36-wave study published in Sustainability tracked 96,784 validated product-market-wave observations across Amazon marketplaces in France, Germany, Italy and the United Kingdom from February to June 2026. It was built around the 27 March 2026 EmpCo transposition deadline and compared 357 EU Ecolabel-certified products with 357 matched comparison products.
After the deadline, in EU markets relative to the UK control, generic environmental claims fell 8.7 percentage points on comparison products and 3.1 points on certified products. Over the same period qualified claims rose 5.9 points, evidence-bearing claims rose 4.4 points, and EU Ecolabel display rose 5.1 points among certified products. The authors distinguish claim withdrawal from signal refinement and conclude that sellers moved toward substantiated messaging rather than silence.
This is a single peer-reviewed study covering one marketplace, so the direction is more reliable than the magnitudes. It is nonetheless the first quantitative counterweight to the greenhushing account of the past year.
Sources: Sağlam & Aygören, Sustainability 18(17), art. 9033 (3 Sep 2026)
Client sectors
Netherlands · GroceryCampaign ran 7–13 September 2026
Every major Dutch grocer ran the same sustainability campaign in the same week
Verspillingsvrije Week, organised by Samen Tegen Voedselverspilling with the Ministry of Agriculture, Fisheries, Food Security and Nature, the Voedingscentrum and Wageningen University & Research, ran nationwide from 7 to 13 September. Albert Heijn, Jumbo, Lidl, Aldi, Dirk van den Broek, DekaMarkt and Plus all took part, alongside food service operators including Compass Group, Sodexo and Albron.
The campaign's headline consumer figures: Dutch households throw away an average of 25.5 kg of food per person per year, and a single waste-free week across all households would save close to 18 million meals.
Simultaneous, near-identical activity across an entire category is a rare natural experiment in whether shared campaigns shift perception of any individual brand within it.
Netherlands · ElectronicsAgenda handed to the minister 3 September 2026
Eighteen Dutch organisations ask the government to make repair the default
The Taskforce Circulaire Elektronicaketen handed an action agenda to Climate and Green Growth Minister Van Veldhoven, targeting a fully circular electronics chain by 2050 with visible results by 2030. Signatories include Consumentenbond, Techniek Nederland, Thuiswinkel.org, Stichting OPEN, Renewi, Natuur & Milieu, NVRD, Fair Resource Foundation and TU Delft.
The asks are rules that actively stimulate repair, reuse and recycling rather than merely permitting them, removal of regulatory barriers, and integration into the Nationaal Programma Circulaire Economie.
Read alongside Finland's new repair obligation, the same pressure is arriving through two different doors within a fortnight: one statutory, one through the organisation that runs the Dutch product tests.
Sources: Consumentenbond (3 Sep 2026)
