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Many traders are taking advantage of consumers’ growing interest in environmental matters because of the climate crisis and are using green claims to differentiate themselves. Many claims are not or cannot be substantiated. This triggers confusion and mistrust among consumers and jeopardizes their active contribution to the transition towards a green economy.

Topsector Logistics The European Green Deal has more forcefully put logistics emissions on the policy agenda of the European Commission. As Topsector Logistics in The Netherlands, we applaud this. As we will explain below, we have been active in reducing transport and logistics emissions in The Netherlands and believe we can contribute to the achievement of the ambitious goals set out.

BEUC, the European Consumer organisation, very much welcomes the publication of the Green Claims Directive as an important step in fighting greenwashing and ending misleading unsubstantiated claims from being displayed on products and services. Consumers are confronted with a systemic greenwashing problem.

BEUC is supportive of the objective of this initiative. However, some principles need to be guaranteed to bring real benefits to consumers: - The methodology should be based on sound scientific evidence and real-world emissions; - The methodology (and the way it is communicated to consumers) should focus on absolute greenhouse gas emissions.

The practical implementation of the accounting of greenhouse gas emissions of transport services has been a focal point for Topsector Logistics (https://topsectorlogistiek.nl/over-topsector-logistiek/) in the last decade. We are pleased to see that the Commission has taken an approach in the proposed regulation that aligns with our practical experience.

Following our initial feedback, BEUC would like to raise new elements: BEUC's main concern is the way in which the data from the methodology will be presented to consumers. In our view, article 9.3 leaves the door open to "disguising" the raw data by stating "the output data as a minimum shall consist total mass of carbon dioxide equivalent (CO2e) per transport service, and, in relation to a type of transport…