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ACM issues guidelines on sustainability claims in the textile industry
28 November 2022

Consumer interest in the sustainability impact of their purchases is on the increase – especially so in respect of clothing. An increasing number of national and international companies in the textile industry uses the High Material Sustainability Index (Higg Index) in their communication about sustainability performance. The Higg Index measures the environmental impact of the materials used in clothing. But to consumers that are not informed about the meaning of the scores awarded on the Higg Index, such scores are unclear and can easily become misleading. This is why the Netherlands Authority for Consumers and Markets (ACM) and the Norwegian Consumer Authority (NCA) have jointly issued guidelines for companies in the textile industry on how to use the Higg Index in their marketing statements.

Although they are based on European regulations on unfair commercial practices, the guidelines themselves are not in and of themselves legally binding. This means that even if a company complies with the guidelines, their marketing activities can still be considered misleading – as underscored by the ACM and NCA.

Higg Index

The Higg Index has been developed by the Sustainable Apparel Coalition (SAC), a global non-profit alliance of stakeholders in the apparel and footwear industry. Through the Higg Index, SAC aims to help the industry identify bottlenecks, improve sustainability performance and achieve the environmental and social transparency consumers are demanding.

The Higg Index provides information on the impact of materials on global warming, fossil fuels, water use, and water pollution. The Higg Index compares the impact of “preferred materials” to their conventional benchmark materials. For example, the impact of organic cotton is compared to conventional cotton fibres. If a garment consists of several types of material, the Higg Index calculates the environmental impact of the full garment’s material composition (each fibre type in the garment is compared to its conventional benchmark material).

Risks associated with sustainability claims

Companies must be truthful in their sustainability claims towards consumers. If they are not, they can be held accountable by consumers / consumer interest groups. The ACM can also take action against companies that claim to be more sustainable than they actually are, for instance by imposing fines. Earlier, we wrote an article (available in Dutch only) on existing ESG regulations and guidelines and the risks ESG poses to the supply chain(s).

In recent years, the ACM investigated sustainability claims in certain industries, including the textile industry. The NCA also conducted several investigations. In one of those investigations, the NCA concluded that a Norwegian trader’s use of the Higg Index in its marketing was misleading and that, in general, using Higg Index scores in marketing can easily be misleading.

Edwin van Houten, Director of ACM’s Consumer Department emphasizes the importance of the guidelines: “We find it positive that the clothing industry is committed to making the environmental impact of its materials more transparent for consumers. This helps consumers make more sustainable choices. It is important that they do so properly so that consumers are not misled. With these guidelines, we explain how businesses can do just that”. 


The guidelines issued by the ACM and the NCA address the following topics:

  1. the documentation and substantiation of sustainability claims based on the Higg Index,
  2. the type of claims that can be made, and
  3. the presentation of claims towards consumers.

If you would like to use the Higg Index for sustainability claims, you are advised to comply with the following recommendations from the guidelines:

  • Clearly state that the scores are global averages and do not apply directly to the production of the specific product.
  • Mention that the scores do not reflect the full impact of materials used, but rather only the impact the materials have in relation to the following four categories:
    • Global warming
    • Fossil fuels
    • Water use
    • Water pollution
    • Indicate that these are figures based on a cradle-to-gate analysis (the sustainability impact from production to sale); not a cradle-to-cradle analysis. This means that the figures do not say anything about the environmental impact of a garment’s full life cycle.
    • Make it clear to consumers that the Higg Index compares the environmental impact within one material type only and not between (different) materials. For example, the impact of recycled polyester is compared to virgin polyester and not to cotton.
    • Ensure that the documents to support the claims are up to date and that the underlying data has been validated by an independent third party.

Van Doorne’s Commercial team closely monitors ESG developments. If you would like to know more about these matters, please feel free to contact Lisette Bieleveld, Florence Verbeek, and/or Albana Mazreku.

ACM issues guidelines on sustainability claims in the textile industry