Environmental claims should be true and sufficiently substantiated. We as an organisation have filed several legal action towards individual actors regarding environmental claims and can confirm that there is a lack of knowledge and enforcement. It is a heavy process to make traders accountable creating disantvantages for both consumers and for companies with well substantiated and relevant claims.
KOA
KTF Organisation AB
Industry association · Sweden
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
5
positions filed
in the 665 files tracked
5
legislative files
of 665 tracked
4
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
KTF Organisation AB filed 5 positions between 14 Mar 2023 and 9 Jul 2025, across 5 of the 665 legislative files tracked here, attaching a full position paper 4 times.
2023 · 3 filed2025 · 2 filed
What they argued
Full feedback provided in attached document. Here follows a summary: Current regulations state that the required labelling information should appear clearly against the background and be easy to read. We believe that the current wording of the regulation should be retained to give companies flexibility to design their labels.
KoHF welcomes the EU COM Proposal for the Revision of the UWWTD and supports its ultimate objectives, in particular: - To protect EU citizens and ecosystems from the remaining sources of insufficiently treated WW. - To better align the EU current rules on UWWT.
KoHF represents the cosmetics and personal care industry in Sweden. Our members represent a significant part of the Swedish cosmetics industry in value, including more than 150 companies, from Micro to Large, global Enterprises. Conclusion The cosmetics legislation key principles have withstood the test of time since 1976.
KTF focuses on three elements that could be improved to ensure that the IAs can effectively contribute to the environmental objectives of the ESPR and the broader competitiveness agenda of the European Commission: VERIFICATION of the disclosed information: KTF recommends verifying the disclosed information through a risk-based approach carried out by national competent authorities using the tools in Article 24(2)…
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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