Offsets and carbon neutral claims under EU Green Claims rules

For product claims, the answer should be no where the neutral, reduced, or positive greenhouse-gas impact is based on offsetting. Directive (EU) 2024/825 amends the UCPD blacklist to cover claims that a product has a neutral, reduced, or positive environmental impact in greenhouse-gas terms when that message is based on offsetting.

The Council Green Claims text uses the same distinction: a product claim may only be built on the product's actual life-cycle impact, not greenhouse-gas offsetting outside the product value chain. Claims such as carbon neutral, climate neutral, CO2 neutral certified, climate compensated, or reduced climate impact therefore need a product-level life-cycle basis, not a purchase of credits standing in for 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.

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 file 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 a stronger file than ordinary ambition language. Directive (EU) 2024/825 treats future environmental performance claims as potentially misleading unless they are backed by clear, objective, publicly available, and verifiable commitments in a detailed and realistic implementation plan.

For a net-zero, carbon-neutrality, or climate-neutrality target, the review should therefore focus on the transition plan, not only the target year. The plan needs measurable and time-bound targets, resources, regular independent third-party verification, and consumer access to the verifier's findings. The Council Green Claims text also treats future environmental performance and climate claims as complex claims, not candidates for a light-touch shortcut.

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.