Offsets and carbon-neutral claims under EU green claims rules

The working rule is not to make offsets carry the main claim. The Green Claims proposal says future environmental performance should prioritise improvements inside the trader's own operations and value chains rather than relying on offsetting. The Council text goes further for climate-related claims by describing offsetting as a risk when it deters reductions in a trader's own operations and value chains.

Before approving a carbon-neutral or compensated claim, require a reduction file that shows the actual emissions boundary, period, lifecycle stage, reduction actions, remaining emissions, and any unresolved data gaps. Offsets can then be described, if at all, as separate supporting information rather than as proof that the product itself has no climate impact.

For climate-related explicit environmental claims, the Commission proposal would require greenhouse gas emissions offsets to be separated from greenhouse gas emissions as additional environmental information. It would also require the trader to say whether offsets relate to emission reductions or removals and to describe how the offsets are high-integrity and correctly accounted for.

Do not collapse this into a single badge or headline. A consumer-facing page should show the emissions result first, then a clearly labelled offset or carbon-credit section that states the quantity, type, period, whether the credit is for a reduction or removal, and how it is accounted for. If those fields are unavailable, the claim should be narrowed or held back.

Directive (EU) 2024/825 is already adopted EU law amending the Unfair Commercial Practices Directive. It adds a black-list item for claiming, based on greenhouse gas offsetting, that a product has a neutral, reduced, or positive environmental impact in terms of greenhouse gas emissions. The recital explains that examples include climate neutral, CO2 neutral certified, carbon positive, climate net zero, climate compensated, reduced climate impact, and limited CO2 footprint.

That matters even while the Green Claims Directive remains a proposal. A product-level neutrality claim based on offsetting is not just a substantiation question under the proposal; it is the kind of consumer claim Directive (EU) 2024/825 was designed to prohibit. The safer presentation is to state the product's actual lifecycle impact and separately disclose any investment in environmental initiatives or carbon-credit projects in a non-misleading way.

Future climate claims are risky because they promise performance that current evidence cannot yet prove. Directive (EU) 2024/825 amends Article 6 of the UCPD so that future environmental performance claims can be misleading where they lack clear, objective, publicly available, and verifiable commitments in a detailed and realistic implementation plan with measurable and time-bound targets, resources, and regular independent third-party verification.

For a net-zero, climate-neutrality, or emissions-reduction-by-year statement, require the implementation plan to be published or otherwise accessible with the consumer claim. The plan should identify the baseline, target year, milestones, resources, technical dependencies, responsible owner, reduction pathway, and the third-party monitoring output. A generic ambition statement should not be used as product marketing.

The Green Claims proposal would require substantiation before communication and would make information about the product or trader, the substantiation, and a clear summary available together with the claim through physical information, a web link, QR code, or equivalent. For offset-backed climate claims, the consumer summary cannot be a technical annex only specialists understand.

The substantiation record should show the claim wording, claim subject, impact category, lifecycle boundary, primary data, representative secondary data where primary data is unavailable, significant impacts considered, offset or credit fields, verifier details where required, and the exact consumer-facing summary. If the claim depends on consumer behaviour in the use phase, the claim should also tell consumers what they need to do to achieve the stated environmental performance.