Netherlands ACM: A Model for German Consumer Protection

The ACM as a model for German authorities: The Dutch Autoriteit Consument & Markt (ACM) has been the strictest consumer protection authority in Europe regarding greenwashing since 2021.

H&M (2023): Order to remove all generic sustainability claims, fine of €250,000. Specifically criticised: the “Conscious Choice” collection without consistent standards.

Decathlon (2022): Withdrew the “Ecodesign” symbol from 429 products. Demanded: concrete sustainability indicators instead of own seals.

Shell (2021): Prohibition of “Compensate” carbon offsetting advertising. A precursor to the EmpCo prohibition of offset claims.

ACM methodology: 1. Automated web crawlers scan e-commerce sites daily. 2. AI-powered evaluation identifies generic environmental terms. 3. Sample audits of suspicious brands. 4. Whistle-blower hotline for employees and competitors. 5. Publication policy: proceedings are accompanied by media coverage.

Transfer to Germany: The DUH and the Verbraucherzentrale (German Consumer Advice Centre) are currently adopting the ACM methodology: automated scans, strategic waves of lawsuits against industry leaders, media coverage as a deterrent. Significance for German companies: generic claims such as “sustainable” will be subject to warning letters from 2026, as in the Netherlands.