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    Sustainable Brand Index
    Sustainability Weekly

    Week 41 ·

    Week 41: the price objection has not moved in a year

    The ban on generic environmental claims has applied in Denmark, Finland and the Netherlands for eight days. Week one suggests the argument has moved rather than ended. Carlsberg brought a Swedish beer to market on the word regenerative, which has no agreed definition and therefore sits on no prohibited list. A Stockholm agency that has screened more than 6,500 claims reports companies still falling into the same category of error. Ipsos finds the share of consumers who say sustainable options are too expensive unchanged at 43 per cent. And Coop Sweden cut the price of 600 items from Monday. The rules have changed the vocabulary; they have not changed the price, and they do not reach words that nobody has yet defined.

    Regulation & policy

    Netherlands · Due diligenceAdvice published 1 October 2026

    ACM says it can police Dutch due diligence, and lists four things it needs first

    The Autoriteit Consument & Markt published its uitvoerbaarheids- en handhaafbaarheidstoets on the draft Dutch bill implementing the EU Corporate Sustainability Due Diligence Directive, an assessment requested by the Minister for Foreign Trade and Development Cooperation. ACM concludes that the bill is workable and enforceable, but attaches four conditions.

    It wants clarity on which third-country businesses fall under its supervision, concrete European guidance for applying the bill's open standards, adequate capacity to supervise effectively, and rapid cooperation between national regulators. Sweden's own due-diligence inquiry, SOU 2026:56, landed three weeks earlier with a deliberately narrow scope, so two of the five markets are visibly diverging on how far due diligence will reach.

    The regulator that took over green-claims enforcement on 27 September would also supervise the due-diligence regime, placing a brand's marketing claims and its supply-chain conduct before a single authority.

    Sources: ACM, UHT ontwerpwetsvoorstel Internationaal Verantwoord Ondernemen, 1 October 2026

    Nordics + NL · Green claims · UpdateWeek one of enforcement, 27 September to 5 October 2026

    UPDATE: eight days in, the five markets are enforcing the same ban differently

    This is an update to the transposition map published in week 40. What is new is not who has the law but how hard each regulator intends to apply it in the first months. On 24 September the ACM told Dutch companies to hold current sustainability claims up to the light, and pointed them at a common understanding published by the EU Consumer Protection Cooperation network at ACM's own initiative.

    That document sets out six principles for stock already on shelves: compliance without delay, staged enforcement where transitional difficulty is genuine, regard for packaging cycles, stock volumes, prior orders and shelf life, reasonable and proportionate company effort such as stickering and point-of-sale corrections, no disproportionate measures, meaning authorities may decline to require destruction or recall, and a compliance-first rather than sanction-first posture early on.

    Denmark's revised recommendations, in force from the same date, state plainly that the new rules also apply to products and packaging produced before 27 September. Norway's Forbrukertilsynet published an updated guide on 21 September saying its own version will probably not commence until the first half of 2027. Dutch fines run to EUR 900,000 per infringement or a share of annual turnover; Norwegian fines to NOK 25 million or 4 per cent of turnover.

    A single claim set running across the Nordics and the Netherlands now carries national rather than European risk.

    Sources: ACM, Vanaf 27 september 2026 strengere eisen aan duurzaamheidsclaims, 24 September 2026 · ACM, Toelichting op de toepassing van de EU-richtlijn duurzaamheidsclaims bij oude voorraden, September 2026 · Forbrugerombudsmanden, reviderede anbefalinger til virksomheders miljoemarkedsfoering, 4 September 2026, in force 27 September 2026 · Forbrukertilsynet, Ny rettleiar for bruk av miljoepaastandar i marknadsfoering, 21 September 2026

    Consumer & brand

    Research · 15 markets · Willingness to payAnalysis published 22 September 2026

    Climate urgency ticked back up. The price objection did not move at all.

    Ipsos published The Sustainability Reality Check, drawn from its Market Essentials Sustainability Report of September 2026, a monthly tracker across 15 countries at 500 respondents each and 1,000 in the United States and Canada. The share saying action on the environment is needed now had fallen from 49 per cent in August 2022 to 40 per cent in May 2026, then rebounded to 43 per cent in August 2026 after a summer of extreme heat, wildfires and drought.

    The gap between concern and self-interest stayed wide: 17 per cent see climate change and natural disasters as a high risk to themselves personally, against 52 per cent who see it as a high risk to the world. Meanwhile 43 per cent say sustainable options are too expensive, unchanged since August 2025, and 56 per cent say governments should put the economy first even where that harms the environment.

    After price, the two largest barriers are confusion and availability: 30 per cent say they do not know which products are sustainable, and 19 per cent say too many of the products they care about do not match the sustainable choices they would like to make. None of the 15 tracked markets is Nordic or Dutch, so the figures set a direction rather than a local benchmark.

    Price appears close to a fixed ceiling in this data. Confusion does not, which makes clarity the more tractable of the two barriers.

    Sources: Ipsos, The Sustainability Reality Check, 22 September 2026

    Sweden · Nordics · Claim screeningAnalysis reported 29 September 2026

    6,500 claims screened, and the agency doing it says firms keep falling in the same place

    Azote, a Stockholm science-communication agency, told Aktuell Hållbarhet on 29 September that it has carried out more than 100 analyses of Swedish and Nordic companies and reviewed just over 6,500 individual environmental claims, combining an AI scanner with expert review. Olav Törnblom, who runs the service, says companies fall into the trap above all within one problem category; the published article does not name which one, and Azote's own counter puts the total number of analyses run through the tool at 1,030.

    The number worth noting is the volume rather than the diagnosis. Pre-publication claim screening has gone from a curiosity to a procurement line for Nordic companies inside roughly a year, and the agency's reading, two days after the ban took effect, is that many have not finished cleaning up.

    Pre-publication claim screening has become a procurement line for Nordic companies inside roughly a year, which is itself a measure of the uncertainty the new rules have created.

    Sources: Aktuell Hallbarhet, Tuffare regler mot gronmalning vantar, 29 September 2026 · Azote, Green Claims Analysis, accessed 5 October 2026

    Client sectors

    Sweden · FMCG · Food and drinkReported 4 October 2026

    Carlsberg picks a word the law has not defined yet

    Carlsberg's brewery in Falkenberg is launching a beer brewed from regeneratively grown malting barley, part of a route to net zero emissions by 2040 and a target that 50 per cent of the raw materials it uses be regeneratively produced by 2032. Sustainability manager Anna Anderberg calls it a very good way to get both sustainable farming and a sustainable beer.

    Unlike organic, regenerative agriculture has no single agreed definition of what may carry the name. Carlsberg has chosen to follow the Sustainable Agriculture Initiative definition, which judges results achieved rather than prescribing exact methods. Gunnar Rundgren, honorary doctor of agronomy at SLU, is among the critics: everyone is sticking this label on because it is hip and cool, he says, and the term has no defined content.

    The prohibition catches generic adjectives. It does not reach a specific-sounding term backed by a private standard, which leaves the credibility of such terms to be settled by consumers rather than by regulators.

    Sources: SVT Nyheter Halland, Darfor satsar Carlsberg pa regenerativt odlad malt till ol, 4 October 2026

    Sweden · GroceryPrice cut effective Monday 5 October 2026

    Coop answers the affordability squeeze with 600 lower prices, permanently

    From Monday 5 October, Stora Coop cuts the price of its 600 best-selling items nationwide by an average of 6.5 per cent. Chief executive Anders Torell says the cut is permanent rather than a campaign, that all 23 consumer societies are participating, and that smaller Coop stores will follow. The examples run from Polarbröd's Polarvete at minus 5.8 per cent through Yoggi yoghurt at minus 9.2 per cent to Delicato balls at minus 15.3 per cent.

    The pressure behind it is considerable. The societies lost a combined SEK 900 million last year and Coop Sverige a further SEK 300 million; market share stands at 16.7 per cent against ICA's just over 50 per cent; and Matpriskollen's mid-August comparison put Stora Coop around 6 per cent above the cheapest rival, Willys. Torell is also the newly elected chair of the trade body Svensk Dagligvaruhandel.

    The chain with the strongest co-operative identity in Swedish grocery has chosen price as its lever, in the same week that research put the cost objection to sustainable options at an unchanged 43 per cent.

    Sources: Dagens Nyheter, Stora Coop sanker priserna med 6,5 procent pa 600 varor, 5 October 2026