The Higg MSI tool is not sufficient as a basis for the environmental claims that outdoor brand Norrøna and fast fashion giant H&M have been using in marketing themselves and their products, the Norwegian Consumer Agency (Forbrukertilsynet) has ruled.
The NCA, in a ruling announced on Thursday, said that Norrøna was breaking the law when they marketed their clothes as environment-friendly. Now, H&M has been issued the same warning against using the same type of marketing.
Norrøna had based its advertising on the industry tool Higg MSI, which measures the environmental impact of various textiles. The NCA has concluded that this tool is not sufficient as a basis for the environmental claims they have used in marketing. It has now sent letters to Norrøna, H&M and Sustainable Apparel Coalition (SAC), supplier of the tool Higg MSI. The letters were marked 14 June.
The claims under question mostly pertained to organic cotton, and the allegation was that the` global average data behind the Higg MSI did not constitute sufficient evidence for the product specific claims.
The NCA wrote to Norrøna Sport AS on 14 February 2022 over the use of the Higg Materials Sustainability Index (Higg MSI) in marketing. Norrøna was asked to present documentation underlying the Higg MSI, which they did on 18 March 2022. An online meeting was held on 5 May, following which the NCA requested for further information, which were provided by Norrøna and the SAC on 27 May.
The NCA has now cited three primary reasons for discarding Norrøna's claims:
- Norrøna’s use of the Higg MSI will likely leave consumers with an impression that the numbers are true, accurate and descriptive of the specific product shown on norrona.com. However, the Higg MSI is based on global average numbers and not on data from the production of the specific product marketed. The Higg MSI being built on global average numbers, means that the reductions in environmental impact shown to consumers for the specific product, are not necessarily correct for the product in question.
- The data underlying the Higg MSI are partly scientifically outdated and not meant for comparisons as done by the use of the Higg MSI.
- The relevant marketing and the Higg MSI does not take into account all relevant ways in which the products are affecting the environment. The “fossil fuels” impact category does not, for example, include emission from manure. If data with respect to other factors that impacts the environment were taken into account, the environmental impact of organic cotton products could be different than what is communicated to consumers in the marketing.
The NCA has asked Norrøna to change or remove the relevant marketing using the Higg MSI from their product pages no later than 14 August.
Some of the points that the NCA made:
- The main problem with using global average numbers, is that such they fail to capture local variations in resource usage and environmental impact. There are significant differences in the way cotton is grown and how much water farmers use, as well as how and if they use these inputs efficiently. For example, climate, rainfall and irrigation technology vary greatly from one farm, country and / or region to another.
- The Higg MSI does not distinguish between rainfed water (green water) and irrigation water (blue water).
- Overall, the Higg MSI is likely to give the average consumer the impression that growing organic cotton always consumes drastically less water and that, mainly due to this, the product has a significantly reduced environmental impact than if the product had been made from conventional cotton. As far as we understand, the real reason behind the substantial reduction in water consumption in global average numbers is because organic cotton farms typically are located in places with more rainfall compared to most conventional cotton farms.
- Thus, the real reason behind the reduction in water consumption is not because organic cotton farms always require less water compared to conventional cotton farms – but rather because of variations in rainfall in the regions where the respective cotton farms are located.