Offsets and carbon neutral claims under EU Green Claims rules

No. A product cannot be marketed as having a neutral, reduced, or positive greenhouse-gas impact where that message is based on offsetting. Directive (EU) 2024/825 requires national measures applying from 27 September 2026 to blacklist that practice. Before then, the existing UCPD can still apply where the same message misleads consumers.

The Directive's recitals say the prohibition does not prevent a product climate claim based on the product's actual life-cycle impact rather than offsets outside its value chain. That does not automatically make the claim lawful: the evidence and overall presentation must still support it. Claims such as carbon neutral, climate neutral, CO2 neutral certified, climate compensated, or reduced climate impact cannot use purchased credits as proof of the product's own impact.

Separate the emissions-reduction evidence from the credit evidence. The Council text says climate-related claims that use carbon credits should consider credits separately from the trader's or product's greenhouse-gas emissions, including financial contributions to carbon-credit projects that are not used for offsetting.

A useful review file therefore has two ledgers: one for actual emissions and reductions in the product, operations, or value chain, and one for credits or contributions outside that boundary. The claim should not let the second ledger change the first.

Classify the proposed wording before reviewing evidence. A product-impact claim based on greenhouse-gas offsetting reaches the Directive (EU) 2024/825 prohibition. A statement about a separately funded climate project can describe the investment without changing the product footprint. A trader-level offset or contribution claim needs its own organisation boundary, emissions inventory, credit disclosures, and UCPD review; the Council's detailed route remains proposal-stage.

Substantiation should start with the claim's exact wording. If the wording says or implies a product or trader has a lower, neutral, positive, or improving climate impact, the evidence needs to support that message with widely recognised scientific evidence, relevant methods, and a life-cycle or activity boundary that fits the claim.

For Green Claims review, the record should also show that relevant environmental impacts were not ignored, that one benefit was not achieved by shifting harm to another life-cycle stage, and that carbon credits were assessed for integrity and correct accounting instead of being treated as equivalent to reductions in the trader's own operations or value chain.

Future environmental performance claims need more than ambition language. From 27 September 2026, national measures implementing Directive (EU) 2024/825 add a case-by-case misleading-practice test for future-performance claims lacking clear, objective, publicly available, and verifiable commitments in a detailed and realistic implementation plan.

For a net-zero, carbon-neutrality, or climate-neutrality target, review the transition plan as well as the target year. It needs measurable, time-bound targets, resources, regular independent verification, and consumer access to verifier findings. The UCPD misleading-practice assessment also considers whether the practice causes or is likely to cause a transactional decision the average consumer would otherwise not take. Council Article 3a(3) excludes future-performance and climate-related claims from the future less-complex-claims branch; other Specific Technical Documentation branches are separately defined.

The communication should make the claim narrower, not broader. Consumers should be able to tell whether the claim concerns the whole product, one life-cycle stage, a trader's operations, a value-chain reduction, an external carbon-credit purchase, or a future target.

Avoid absolute wording when the evidence is partial. The Council Green Claims text says wording, imagery, layout, colours, symbols, and labels should truthfully represent the scale of the environmental benefit and should not overstate it. The older Commission compliance criteria make the same practical point: clear qualification matters because broad environmental-benefit claims are difficult to substantiate and can mislead consumers.