Annex I, point 4c
The carbon neutral claims ban
What the ban says
Short answer
It is banned in all circumstances to claim that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions, when that claim is based on offsetting emissions outside the product's value chain.
Note the two triggers. One: the claim is about a product, a good or a service. Two: it rests on offsetting. Both must be present. This is a blacklist ban. Authorities do not need to prove anyone was actually misled. The practice is simply prohibited.
Key takeaways
- Banned wording examples from the directive: climate neutral, CO2 neutral certified, carbon positive, climate net zero, climate compensated, reduced climate impact, limited CO2 footprint, when offset-based.
- The Commission's example case: a flight marketed as climate neutral because the airline invests in rainforest reforestation. Prohibited.
- Offsetting emissions elsewhere is not the same as your product causing no emissions. That mismatch is the whole point of the ban.
- Company-level offset claims escape this specific ban but still face the general misleading rules.
- Real lifecycle-based claims stay possible, with proper life cycle assessment as proof.
Banned vs still possible
| Claim | Status | Why |
|---|---|---|
| "This flight is climate neutral" (offset projects) | Banned | Product claim based on offsetting. The Commission's own example of a breach. |
| "CO2 neutral certified" on a sneaker (offset-backed) | Banned | Certification does not save it. The basis is still offsetting. |
| "This product stores more CO2 than its value chain emits" | Possible | Allowed when a proper life cycle assessment proves net storage, as with some biomass products. |
| "We cut manufacturing emissions 50% since 2020" | Possible | A real, verifiable reduction in your own operations, specified on the same medium. |
| "We invest in certified carbon removal projects" | Possible | Honest communication about investments, without framing the product as neutral. |
| "Carbon neutral by 2030" | Conditional | Needs a public, detailed, funded plan with measurable targets, verified regularly by an independent expert. |
Future promises: net zero needs a plan
Claims about future environmental performance get their own rule in Article 6 of the UCPD, the same case-by-case test behind most greenwashing cases. Think "carbon neutral by 2030" or "plastic free by 2028". These are assessed case by case. They fail unless you have all of this:
Clear, objective, publicly available and verifiable commitments. A detailed and realistic implementation plan. Measurable and time-bound targets. Resources allocated to make it happen. And regular verification by an independent third-party expert whose findings are made available to consumers.
The Commission adds practical detail in its June 2026 Q&A. The expert can be a private auditor or consultancy. The plan does not need to sit on the packaging. A QR code pointing to it is fine. What counts is easy access and genuine independence.
The rules apply from 27 September 2026
That includes products already on the shelf. Check your claims, labels and product pages now, not after enforcement starts.
Frequently asked questions
Is 'carbon neutral' banned in the EU from 2026?
Offset-based carbon neutral claims about products are banned from 27 September 2026. That covers claims like climate neutral, CO2 neutral certified, carbon positive, climate net zero and climate compensated when they rest on offsetting emissions outside the product's value chain. Claims based on the product's real lifecycle impact are not covered by this specific ban, but they need robust evidence.
Why does the EU ban offset-based climate claims?
Because they mislead. Saying a product is climate neutral suggests buying it has no climate impact. In reality the emissions still happen. The company just pays for reductions somewhere else, often with uncertain effect. The Commission's example: calling a flight climate neutral because the airline funds rainforest reforestation. That claim is now blacklisted.
Can a company still talk about carbon offsetting at all?
Yes. The ban targets product claims built on offsets. Companies can still communicate about their investments in environmental projects, including carbon credits, as long as they present them honestly and do not frame the product as neutral because of them. Company-level offsetting claims fall outside the specific blacklist point, but the general misleading rules still apply.
Are lifecycle-based carbon claims still allowed?
They can be. The Commission notes some products genuinely store more CO2 than their value chain emits, for example certain biomass-based products. Such claims must be substantiated with proper life cycle assessments. Claims like 'we cut our production emissions by 50% since 2020' remain possible when they reflect real, verifiable reductions and are specified clearly on the same medium.
Can I say 'carbon neutral by 2030'?
Only with receipts. Future climate promises are misleading unless backed by clear, objective, publicly available and verifiable commitments, set out in a detailed and realistic implementation plan with measurable, time-bound targets and allocated resources. An independent third-party expert must regularly verify progress, and the findings must be available to consumers.
Who counts as an independent third-party expert for future climate claims?
The directive does not name a specific body. The Commission says the expert must be independent from the trader, free from conflicts of interest and competent in environmental issues. Private auditors or consultancies can do it. Reviews should be regular, with annual or biennial checks suggested as good practice. Findings can be shared via a link or QR code, as long as consumers can easily reach them.
