Week 39 ·
Week 39: Sweden's e-commerce trust mark failed its own audit
Consumers rarely verify sustainability themselves; they delegate it to intermediaries. This week four of those intermediaries were shown not to be doing the checking: Sweden's e-commerce trust mark, whose holders are now largely under supervision; Dutch energy "comparison services" that turned out to be sales channels; resale platforms carrying roughly five times the footprint of a charity shop; and the Dutch regulators themselves, publishing budget cuts and an explicit list of what they will stop watching. The EU's rules on environmental claims apply in six days.
Regulation & policy
Sweden · CertificationEvent: 17 September 2026
Sweden's e-commerce trust mark failed its own audit: 46 of 50 holders
Konsumentverket reviewed the contract terms of 50 online retailers carrying Svensk Handel's Trygg E-handel certification and found unfair terms at 46 of them. The problems clustered in three places: clauses disclaiming liability for pricing errors after a purchase is made, clauses denying responsibility for inaccurate product descriptions and images, and blanket force-majeure and damage exclusions that Swedish consumer law does not permit.
The authority has opened supervision proceedings against all 46 and given them until the end of September to return remediation plans. Swedish trade press named Elgiganten, Clas Ohlson and Stadium among those reviewed. The certification scheme is administered by the retail trade body itself.
The finding arrives six days before the EU rules on environmental claims apply, under which a sustainability label without recognised performance behind it becomes an unfair commercial practice in its own right.
Sources: Konsumentverket (17 Sep 2026) · Market.se (17 Sep 2026)
Netherlands · EnergyEvent: 11 September 2026
ACM tells every Dutch energy supplier to stop using fake comparison services
ACM wrote to all energy suppliers after investigating telephone sales in which agents introduce themselves as independent price comparators while being paid by a supplier. Suppliers must show ACM what they are doing to stop the practice, and remain responsible for their entire sales chain including contracted third parties. No companies were named and no fines were issued.
ACM's framing was blunt: energy contracts are complicated products that should not be concluded on the back of an unsolicited phone call.
The failure sits in the verification layer rather than the product: the service a consumer uses to check a supplier turns out to be that supplier's sales channel.
Sources: ACM (11 Sep 2026)
Netherlands · Enforcement capacityEvents: 15–16 September 2026
Dutch supervisors publish, in the same week, what they will stop watching
The ILT sent its 2027 annual plan to parliament on 15 September with a €251.6m budget. PFAS in water, environmental crime, soil quality and products entering the Netherlands from non-EU webshops are named growth priorities; oversight of dangerous-goods transport, taxis and rail and aviation noise is scaled back. Inspector-General Mattheus Wassenaar: "We can no longer offer the same level of oversight everywhere."
A day later the Consumentenbond criticised the 2027 budget for cutting ACM's funding from 2028 and taking the data protection authority from €60m in 2026 to under €49m a year by 2028, against a stated requirement of €100m.
The EU green-claims rules therefore arrive in a supervisory system that has just published its triage list, which points to selective rather than broad enforcement in the first year.
Sources: ILT Jaarplan 2027 (15 Sep 2026) · Consumentenbond (16 Sep 2026)
Sweden · Due diligenceEvent: 17 September 2026
Sweden's due-diligence inquiry lands, and the scope is very small
The Swedish government inquiry on corporate sustainability due diligence delivered its report (SOU 2026:56) on 17 September, proposing how the EU due-diligence directive is written into national law: companies must identify, prevent, limit and remedy human-rights and environmental harm in their own operations and value chains.
Thresholds after the Omnibus reset are high: more than 5,000 employees and global net turnover above €1.5bn, with non-EU companies captured at €1.5bn of EU turnover, and franchise and licence structures pulled in where royalty and turnover tests are met. The report now goes to consultation.
Few Swedish consumer brands clear those thresholds, which leaves supply-chain accountability for most of the market voluntary and reputational rather than statutory.
Sources: Regeringen.se (17 Sep 2026)
Consumer & brand
Research · SwedenEvent: 18 September 2026
Told what was in the product, Swedish purchase intent halved
IVL Svenska Miljöinstitutet published a mapping of directly imported consumer goods combining laboratory testing with a consumer survey. Testing across four categories found lead and phthalates in electronics, PFAS, dyes and heavy metals in textiles and footwear, and cadmium, lead, nickel and mercury in jewellery.
More than 70% of consumers who had previously bought from foreign e-commerce platforms said they would buy again, falling to 35% once they were told the products do not meet EU safety and chemical requirements. Around 5.9 billion low-value consignments (under €150) entered the EU in 2025. Project lead Amanda Martvall noted that chemical content, unlike poor quality, is not visible to the buyer.
Purchase intent halved on information alone, with no change in price, values or availability: a finding about disclosure rather than about consumer attitudes.
Sources: forskning.se (18 Sep 2026) · IVL report
Netherlands · Belgium · ResaleEvent: 11 September 2026
Oxfam puts a number on the gap between two things both called "second-hand"
Oxfam published lifecycle calculations by the consultancy RDC Environnement comparing 5 kg of clothing through three second-hand channels: 0.6 kg CO₂ through solidarity and thrift shops, 2.9 kg through commercial second-hand retailers and 3.1 kg through digital resale platforms, using Vinted as the worked example, roughly a fivefold gap between the charity shop and the platform.
Oxfam's argument is not that resale is harmful but that platform models can generate additional consumption rather than displacing it, so volume through a resale channel is not by itself an environmental gain.
The figures make "circular" a channel-specific claim rather than a category-wide one, at the point where generic environmental claims lose their legal cover.
Sources: RetailDetail, reporting Oxfam / RDC Environnement (11 Sep 2026)
Client sectors
Fashion · Retail · Circular economicsEvents: 16–17 September 2026
Three circular businesses moved in two days, and the two that survived were attached to something else
Hollands Wol Collectief, the Dutch venture built to turn domestic sheep wool into a local textile chain, announced on 17 September that it stops trading on 1 November. Founder Janne de Hoop gave a price explanation: "alternatieven zijn simpelweg te goedkoop", the alternatives are simply too cheap.
In the same 48 hours two circular services expanded. Nudie Jeans opened its repair service to denim from competing brands on 16 September, turning an own-brand loyalty service into open infrastructure. Decathlon began re-leasing refurbished lease bikes in the Benelux on 17 September at up to 60% below the price of a new bike, with a two-year warranty.
The distinction is structural rather than communicational: the models that scaled were attached to an existing revenue engine, while the one that closed had to beat virgin material on price alone.
Sources: FashionUnited NL (17 Sep 2026) · Habit (16 Sep 2026) · RetailDetail (17 Sep 2026)
