“Climate neutral” and carbon offset claims: what the EU bans from September 2026
Point 4c of the new EmpCo blacklist bans one of the most common green claims in e-commerce: saying a product has a neutral, reduced or positive impact on greenhouse gas emissions because of carbon offsetting.
In short
- Banned: product claims like “climate neutral”, “CO2 neutral”, “carbon positive” or “climate compensated” when they rely on offsetting.
- Also covered: wording with the same meaning, labels and icons, and claims about delivery or packaging of the product.
- Still possible: transparent statements that you fund climate projects, without claiming the product's impact is neutral.
- Reductions in your own value chain can be described, specifically and with evidence.
The exact rule
EmpCo adds point 4c to Annex I of the Unfair Commercial Practices Directive. It bans claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.
Because it is on the Annex I blacklist, there is no balancing test. If the claim exists and relies on offsetting, it is unfair, no matter how high the quality of the carbon credits or how clearly the scheme is explained.
What is covered
- Words: climate neutral, carbon neutral, CO2 neutral, net zero product, climate positive, carbon negative, climate compensated, offset delivery.
- Translations and variants: klimaneutral, CO₂-neutral, neutre en carbone, a emissioni zero, klimatneutral, and so on.
- Labels and icons that say the same thing, including third-party offset labels on product images.
- Claims about part of the product offer, such as “climate neutral shipping” or “CO2-compensated packaging”.
The ban targets claims about products. Statements about a company's general climate strategy are not on the blacklist, but they are still judged under the general rules against misleading claims, and future targets need a verified implementation plan.
What you can still say
| Avoid | Consider instead (if true and documented) |
|---|---|
| “Climate neutral T-shirt” | “We fund certified reforestation projects. This does not reduce the emissions of this T-shirt.” |
| “CO2-neutral delivery” | “Delivered by electric vans in Berlin and Hamburg.” |
| “Carbon positive brand” | “We cut emissions from our own production by 30% between 2022 and 2025, measured by [method], verified by [verifier].” |
Recital 12 of EmpCo makes the distinction: businesses may still advertise their investments in environmental initiatives, including carbon credit projects, as long as they do so in a way that is not misleading and does not claim the product's impact is reduced or neutral because of them.
Reduction claims based on your own value chain
The ban is about offsetting. If emissions really fell in the product's own life cycle, for example through a lower-carbon material or a more efficient factory, you can say so. Be specific about what was reduced, by how much, compared with what, and how it was measured. Vague versions of such claims run into the generic claims ban instead.
Checklist before 27 September 2026
- Search your store, apps and email templates for neutrality wording in every language you sell in.
- Remove offset labels from product images and badges.
- Check shipping apps and checkout add-ons that show “carbon neutral shipping” messages.
- Rewrite any remaining climate statement as a specific, verifiable fact.
- Brief your marketing team and agencies: the same rule applies to ads and social posts.
Sources
- Directive (EU) 2024/825, Annex point 4c and recital 12, EUR-Lex
- Regreener: Green Claims Directive status and what applies instead
This guide explains EU rules in general terms and is not legal advice. National rules and guidance can add requirements. Check the sources and, for your specific products, ask a lawyer or the competent authority. Last checked 31 October 2026.