What looks wrong
A garment hangtag that reads like a lab result: this fabric used less water, less carbon, trust us.
What’s actually going on
In June 2022 the Norwegian Consumer Authority wrote H&M that using Higg Materials Sustainability Index data in consumer marketing would easily be considered misleading. The authority had already barred another brand from using Higg MSI numbers that way. The problem was not a secret spreadsheet. It was selling global averages as if they described the shirt in your hand.
Fast fashion learned to speak in percentages. A shirt is not just cotton. It is '20% lower climate impact' according to an industry index most shoppers have never heard of. The hangtag does the work a government eco-label would do, without being one.
Norway's Forbrukertilsynet spent 2022 on exactly that move. After ruling that outdoor brand Norrøna's Higg MSI-based claims were misleading, it sent H&M a letter: using Higg MSI data toward consumers 'easily will be considered misleading' under the Marketing Control Act. The authority had not finished a product-by-product case against H&M. It was warning the method.
The method's flaw, later spelled out with the Dutch ACM, is average-versus-this-garment. Higg MSI scores are industry tools built on global averages for fiber types. Printed on a specific SKU, they read like a lab test of that SKU. The Sustainable Apparel Coalition paused consumer-facing Higg use after the Norwegian action.
This is a claim about a label, not about the people who wear the clothes. If a score cannot be tied to the object in the bag, the honest move is to take the hangtag off.
Source: Norwegian Consumer Authority letter to H&M on Higg MSI marketing, June 2022 (PDF). We quote the public record. A settlement is not always an admission.