SAC Response to the Guidance Document from the Norwegian and Dutch consumer authorities

Clothing rack in a design studio
October 11, 2022

San Francisco, Amsterdam, Hong Kong – October 11, 2022: The Sustainable Apparel Coalition (SAC) has today issued a statement in response to the Guidance Document from the Norwegian and Dutch consumer authorities. The full statement follows:

The Sustainable Apparel Coalition is united with the Norwegian Consumer Authority (NCA) and the Netherlands Authority for Consumers and Markets (ACM) on the need for environmental information shared with consumers from apparel and footwear brands to be credible, accurate and substantiated. Only by the industry working together with policy makers and regulators can the scale of the change that is needed be achieved.

We are grateful for the collaboration and productive discussions we have had with the NCA and ACM. Following these discussions, the Dutch and Norwegian authorities have issued guidance solely for “…the use of the Higg MSI in marketing measures and the presentation of the Higg MSI data towards consumers”. While also intended to be of use for all traders in the industry who wish to include environmental claims in their marketing to consumers, the guidance document does not relate to any of the other Higg Index suite of tools, which continue to be used extensively by the apparel and footwear industry to drive positive social and environmental improvements in global supply chains.

Based on the authorities’ interpretation of current EU law, the guidance does not represent a formal legal framework or ruling and is not legally binding on the authorities or the Sustainable Apparel Coalition. This means that the important task now is for us to work through this guidance with legal and topic experts to explore the feasibility of application while ensuring any resulting methodology and communications are in line with the wider European framework.

The Sustainable Apparel Coalition’s role is to establish common ground with all parties of the apparel and footwear industry and work with our members to lessen their impact. We enable brands, retailers, and manufacturers to measure, improve and share their sustainability performance.

To assist the industry in moving forward, we need harmonized regulations and clear, coordinated information on how information can be presented to consumers. Our ambition, following the next phase of collaboration with the NCA and the European Commission, is to provide guidance for our members, and the wider industry, to ensure all environmental claims are as robust as possible.

As previously announced, we have commenced a third-party expert review of the Higg MSI to further evaluate and develop the tool. We are also doubling down on our efforts on critical data collection from across the material industries.

— Ends —

About the Sustainable Apparel Coalition:

The Sustainable Apparel Coalition (SAC) is an independent and impact-creating organization that aims to lead the industry toward a shared vision of sustainability based upon a joint approach for measuring, evaluating, and improving performance.

As a non-profit organization, it has members from across the apparel, footwear and textile sector, but exists independently outside any one company so that it can drive progress. The SAC’s collective action efforts bring more than 280 global brands, retailers, manufacturers, NGOs, academics and industry associations together. They represent about half of the apparel and footwear industry along the whole supply chain – from sustainability pioneers to organizations just getting started.

Before the SAC existed, companies worked in a siloed way, using their own programmes and measurements that lacked standardization and an ability to drive collective action. In 2009, Walmart and Patagonia identified this as a serious problem. Joining forces, they brought together peers and competitors from across the sector, to develop a universal approach to measuring sustainability performance and founded The Sustainable Apparel Coalition.

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