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Dutch regulator steps up anti-greenwashing enforcement in food industry

The Netherlands Authority for Consumers and Markets has warned food companies to tighten sustainability claims.

In a letter to the industry issued in late April, the Autoriteit Consument & Markt (ACM) noted that there are many “unclear claims” being made in the food sector.

Edwin van Houten, director of the consumer department at the ACM, said: “Many foodstuffs are promoted with all kinds of sustainability claims, labels, logos, and quality marks.

“We see sustainability claims that concern environmental aspects, but also claims about working conditions or animal welfare. It is not always clear what the claim exactly entails or what the logo stands for.”

He added: “[O]nly honest and clear claims help consumers make the right choice if they want to take sustainability into account.”

Specific, measurable, and evidence-based

The regulator said that sustainability claims must be specific, measurable, and supported by evidence to avoid misleading consumers.

The warning follows the ACM’s updated Leidraad Duurzaamheidsclaims (Sustainability Claims Guidelines), issued in 2023, and anticipates new European Union rules taking effect in September 2026​.

Jellien Roelofs, a lawyer and green claims consultant at Lasting Legal, a consultancy that advises companies on environmental and sustainability communication compliance, told Ingredients Network: “The ACM expects companies to present a detailed plan for achieving their stated ambitions.

“This plan should outline specific, measurable actions and include strategies for the continuous improvement of the product, service, or company.”

Roelofs added that “the implementation of this plan should already have commenced or should commence in the near future”.

From September 2026, companies communicating sustainability ambitions will be required to undergo regular third-party assessments under the amended Unfair Commercial Practices Directive.

No more ‘climate friendly’ claims

The ACM said that food companies must avoid vague or misleading language that could confuse consumers​.

Terms like “sustainably grown” or “climate friendly” are not acceptable unless the specific sustainability benefit is immediately clear.

In its guidance, the ACM gave examples of acceptable claims, such as: “Our cows spend 200 days a year outdoors, which is 40 days more than the national average”​.

In contrast, general statements such as “responsibly sourced” or “better for the environment” are considered potentially misleading unless properly substantiated​.

“One particularly challenging practice is the claim that a product is ‘carbon neutral’,” said Roelofs. “Achieving so-called carbon neutrality invariably involves carbon offsetting, and consumers often find such claims highly confusing.”

She noted that from September 2026, carbon neutrality claims will be explicitly prohibited for individual products.

The ACM also warned against suggesting that legal requirements or standard practices represent unique sustainability advantages. For example, a claim that paper is “free from tropical hardwood” is misleading because tropical hardwood is not used in paper production​.

Company-specific sustainability logos discouraged

The ACM has also raised concerns about confusing company logos that could be misleading consumers​.

Roelofs explained: “The ACM refers to company logos that resemble sustainability labels. Such visuals, used for internal company initiatives, are often misleading as they may falsely create the impression that the company or its products have been independently certified.”

One example cited by the ACM is the use of green leaf imagery on packaging without further explanation​.

From September 2026, any sustainability label not based on a third-party certification scheme will be prohibited. Roelofs advised aligning company initiatives with new requirements or avoid initiating such activities altogether.

The European Commission’s proposed Green Claims Directive, which would mandate pre-approval of environmental claims, is still under negotiation and not expected to apply before the end of 2027, but other European countries are likely to issue stricter national guidance before then.

The ACM made it clear that it would focus additional enforcement efforts on the food and beverage sector throughout 2025​.