H&M Group

H&M Group operates no installations registered under the EU ETS, so the EUTL ground-truth emissions database — Prasine's primary verification source — could not be used to independently check absolute emissions against the claim. This is a confirmed data gap, not evidence of concealment.

The claim itself is better-constructed than many corporate net-zero pledges: it names a specific baseline year (2019), a specific reduction percentage (90% absolute, covering Scope 1, 2 and 3), reports interim progress (41% Scope 1+2, 35% Scope 3), specifies permanent removals rather than offset credits (aligning with the EmpCo Directive's core distinction), and references SBTi validation. The SBTi record confirms "Targets set" status with a 1.5°C classification and a net-zero target component, providing moderate support (confidence 0.70).

However, the source document analysis (confidence 0.95) identifies material substantiation gaps: no disclosed absolute baseline emissions in MT CO2e, no breakdown of the abatement-to-removal split, and no description of the certified removal mechanisms (e.g. DAC, BECCS, biochar) that would underpin the "permanent carbon removals" language. Without these disclosures, the claim cannot be independently verified against the EmpCo Directive's substantiation standard, despite its structural sophistication relative to generic pledges.

This is not a repeat claim — H&M Group has one prior Prasine assessment and no history of repeat violations on this specific claim, which is a mitigating factor. No lobbying contradiction was identified: the EU Transparency Register lookup and LobbyMap data were unavailable for this assessment, so lobbying alignment could not be assessed (a data gap, treated as neutral, not obstructive).

(b) Green Claims Directive (enforcement begins September 2026): Under GCD's mandatory independent verification requirements, this claim would require third-party substantiation of the baseline emissions figure, the abatement-to-removal ratio, and the certified removal methodology before publication. As currently disclosed, the claim would likely fail GCD scrutiny absent additional disclosure of these elements.

Under UCPD Article 11 (as amended by the EmpCo Directive, EU 2024/825), this claim is subject to enforcement by national consumer protection authorities. As H&M Group's EU operations span multiple member states, complaints may be filed with the relevant national consumer protection authority in the jurisdiction where the claim is published or marketed (e.g., Sweden's Konsumentverket, given H&M Group's headquarters location).