Norway and Holland issue guidelines on Higg MSI

AMSTERDAM – New strict guidelines on the use of the Sustainable Apparel Coalition’s Higg MSI tool in marketing appear to make the use of Higg untenable as a basis for consumer-facing eco-labels. The guidelines have been drawn up by Norwegian Consumer Authority (NCA) and Dutch Authority for Consumer and Markets (ACM). They include a range of stringent caveats for the SAC if they want the Higg MSI to be used by fashion to underpin green claims.

The guidelines are intended to bring use of Higg MSI in line with existing adverting rules in the EU/EEA area.

Among them are that the SAC brings in an independent expert to review the Higg MSI (which it is already doing), including its datasets which are outdated and not representative in many cases.

The two authorities have also called for regular independent reviews of the Higg MSI datasets, a process the SAC has shown little appetite for in the past. “If there is significant disagreement in the scientific community with respect to the methodology, correctness and/or relevance of specific Higg MSI data sets, the relevant data sets should not be used for making environmental claims towards consumers through the Higg MSI (or otherwise),” the guidelines say.

They also state that the use of global averages to underpin green claims is “problematic.” Therefore, they state: “In the guidance document, NCA and ACM state that when such data are presented in marketing, it should be clear from the marketing that the numbers presented are global averages. It must be clear to the consumer that the numbers are not directly related to the production of the specific product.”

Given that many within the textile industry struggle with the concept of global averages, it is difficult to see how the nuance relating to this issue will be explained on a consumer-facing label.

The document adds: “The two consumer authorities state that the SAC should engage an independent third party to review data sets underlying the Higg MSI, as well as the Higg MSI methodology. The SAC must make sure that global average numbers presented to the consumer are based on representative and updated data.”

The document also states that when Higg MSI data are used in marketing towards consumers, “the marketing must clearly inform the consumers that the data only concern specific environmental impact categories. It must be clear to the consumer which possible environmental impacts are not reflected in the numbers presented in the marketing.”

The guidelines also say it should be made clear to consumers that the Higg MSI covers only cradle to factory gate, not the full lifecycle of a garment.

The guidelines state: “The Higg MSI numbers are based on a so-called ‘cradle to gate’ assessment. The numbers are meant to show the environmental impacts of a material from the raw materials are grown or made to the fabric is ready for use in a garment. This means the Higg MSI does not measure the environmental impact across the entire life cycle of a material or product (from “cradle to cradle”). This will not be self-explanatory to the average consumer. Therefore, the SAC also needs to make clear to consumers what the measuring of environmental impacts only ‘cradle to gate’ means.”

Trond Rønningen, director of the Norwegian Consumer Authority said: “All traders must make sure they keep their marketing within the limits of relevant laws and directives.

“Traders must be able to document the claims they present in marketing to consumers. As long as you can substantiate your marketing claims and present your message in a way that is clear, concise and understandable for the average consumer, you should be in the clear.

“It is positive that the textile industry wants to display credible data about the materials used in garments in their marketing to consumers. However, it is important that any claims about the environmental impact of garments and textiles are correct. Such claims must be substantiated by correct and sufficient data, and not presented in a misleading way.”