Week 40: The green-claims ban is law in three of five markets

Directive (EU) 2024/825, the rules banning generic environmental claims, offsetting-based climate-neutrality claims and self-awarded sustainability labels, became applicable across the EU on 27 September. In Denmark, §§1–2 of LOV nr 558 af 27/05/2025 commenced the same day, with no sell-through provision in the statute. In the Netherlands the Implementatiewet richtlijn betere duurzaamheidsinformatie voor consumenten (Stb. 2026, 152) took effect on the same date; ACM set out its enforcement line on 24 September, with board member Martijn Ridderbos calling on companies to review existing claims critically. Finland's Act 573/2026 also commenced on 27 September, but claims and markings on goods or packaging placed on the market before that date have until 27 March 2027 to comply.

Sweden and Norway did not arrive at the date. Sweden has no transposing bill: the vehicle remains the inquiry report SOU 2025:124, which proposes entry into force on 1 January 2027, and Konsumentverket's guidance states that it is awaiting national legislation. Norway's act (LOV-2026-06-19-34) was sanctioned on 19 June 2026 but has not been commenced, with Forbrukertilsynet expecting the first half of 2027 pending EEA incorporation. The Commission marked the application date with a preliminary Q&A on 22 September rather than formal guidance. Its substance is notable: brand and product names can themselves constitute environmental claims, and packaging imagery such as leaves or water drops can be an implicit claim.

KKV opened a public consultation on a draft guideline titled Vastuullisuus- ja ympäristöväittämät markkinoinnissa, "responsibility and environmental claims in marketing", with comments due by 18 October 2026. The word vastuullisuus means responsibility rather than environment, and the Finnish scope accordingly reaches claims about labour conditions, wages, workplace safety and human rights alongside environmental ones. The draft requires marketers to state explicitly whether a claim covers the whole product, the packaging, a service or the company's operations, and to name and evidence the specific benefit claimed, citing the EU Ecolabel and the Nordic Swan as acceptable support.

The draft incorporates Directive 2024/825 and the Ombudsman's recent decisions, and was published four days before the Finnish rules took effect. Guidance issued in draft, at or after application, is the pattern across all five markets this month: the Netherlands is still working from a 2023 Leidraad, Denmark reissued its recommendations on 4 September, and Sweden has published nothing new since December 2025.

The Commission's September infringement package (INF/26/1834) sent letters of formal notice to Sweden and the Netherlands, among others, for failing to transpose the Right to Repair Directive (EU) 2024/1799 by its 31 July 2026 deadline. Both have two months to reply. The package contains no decision on the green-claims directive; the live action there remains the letters of formal notice issued to 20 member states on 28 May 2026, a list now materially out of date since the Netherlands, Finland and Austria have transposed in the interim.

In Sweden, SOU 2025:124 is the single vehicle for both the green-claims directive and right to repair, so the country is now formally on notice for one half of an inquiry whose other half has also missed its deadline, with no proposition before the Riksdag.

Klimat- och näringslivsdepartementet sent Naturvårdsverket's draft legislative amendments for extended producer responsibility for textiles out for consultation (diarienummer KN2026/01849), with responses due 30 December 2026. Scope covers textiles, textile-related products and footwear for household use. Producers would finance collection, sorting and treatment for products first placed on the market after the system starts, with legacy textiles remaining a municipal responsibility; producers not established in Sweden must appoint a Swedish representative.

The most consequential provision for retail is the platform duty: online marketplaces and fulfilment providers established in Sweden would have to verify that sellers are registered and compliant before allowing sales, and cut off those who are not. The EU requires the system to be operational by 17 April 2028, with Swedish legislation due by June 2027 and microenterprises brought in by April 2029.

Miljømærkning Danmark released a new instalment of its Nordic Consumer Sustainability Index, conducted by Opinion with fieldwork from 11–30 January 2026 across 4,368 Nordic consumers, of whom 1,010 were Danes aged 16 and over. 39% of Danes name environment and climate as one of the major challenges facing their country, against 17–28% across the other Nordic markets. Separately, 73% of Danes say they have observed climate change in their own local area: shifting seasons 34%, more rain 31%, higher temperatures 25%, less snow and more flooding 24% each, stronger storms 19%. And 44% name climate change as the single greatest environmental challenge.

Two qualifications apply to any use of these figures. The fieldwork dates from January and is therefore eight months old at publication; and the greenwashing findings often attached to this index (82% saying companies exaggerate, 84% wanting third-party certification) come from the May 2026 instalment, not this one.

GlobeScan, commissioned by WWF, surveyed 350 senior business executives across European sectors and geographies, with fieldwork in June and July 2026. 91% said transitioning to a low-carbon, environmentally sustainable economy strengthens long-term competitiveness. On the EU's simplification agenda, 29% reported positive impacts while 55% reported negative or mixed ones; of the latter group, 57% cited increased policy uncertainty as the consequence. Asked to name their top competitiveness priority, 43% chose predictable and coherent EU policy and legislation, ahead of every other option, and 56% said the EU is unlikely to meet its key sustainability goals under current conditions.

This is an executive survey rather than a consumer one, and it was commissioned by an organisation with a stated position on the simplification package, and both are relevant when weighing it.

Thuiswinkel.org and bol jointly published a Handleiding duurzaamheidsfilter, a manual for building sustainability filters and product labelling compatible with the new rules, developed under ACM supervision. ACM board member Martijn Ridderbos, Thuiswinkel.org director Marlene ten Ham and bol's ESG director Dennis van den Berg are all attached to it. The concrete change inside it: bol has retired its single in-house "Goede Keuze" label and replaced it with more than twenty specific labels covering individual verifiable attributes, and extended the filter to display warranty period and repairability.

A self-awarded label without independent verification is among the practices the directive prohibits. That a dominant Dutch marketplace dismantled its own mark ten days before application, and published the method as a template with the regulator's involvement, makes this a working benchmark for the sector rather than trade-body positioning.

The Commission published its draft list of non-OECD countries authorised to continue importing EU non-hazardous waste, having assessed requests from 32 applicant countries, with an online consultation open until 16 October 2026. The ban on plastic-waste exports to non-OECD countries takes effect on 21 November 2026, the general non-OECD export ban follows on 21 May 2027, and the first authorised list is to be finalised by the end of 2026. In 2025 the EU exported 1.4 million tonnes of plastic waste: Türkiye 510,000 tonnes, Malaysia 276,000, Indonesia 215,000, Vietnam 137,000 and the United Kingdom 108,000.

The timing places two things in the same quarter: recycling capacity outside the bloc becomes constrained in eight weeks, while "recyclable" and "recycled content" claims become individually enforceable under rules that took effect this week.