From 27 September 2026 the EU effectively bans "carbon neutral," "climate neutral," and "net zero" claims on products when the underlying reduction is achieved primarily through offset purchases rather than value-chain emission cuts. Annex I point 4f of the amended Unfair Commercial Practices Directive lists this as a commercial practice "unfair in all circumstances" — a blacklist that requires no case-by-case proof of consumer harm.
Businesses that have built their climate communication around these terms now need replacement language. This page lists 12 alternatives, grouped by defensibility tier, each with the specific evidence requirement that makes it compliant.
What the Ban Actually Prohibits
Annex I of Directive 2005/29 (as amended by ECGT 2024/825) adds point 4f: "Making an environmental claim related to future environmental performance, without clear, objective, publicly available and verifiable commitments... including an implementation plan... and monitoring by a third-party expert." And point 4d: claiming a product has a "neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions on the basis of offsetting of greenhouse gas emissions outside the trader's value chain."
The practical effect:
- "Carbon neutral" or "climate neutral" on a product based on offsets → banned.
- "Net zero by 2050" with no interim targets or plan → banned.
- "Carbon neutral company" without a transition plan → banned.
- Reduction claims based on actual value-chain emission cuts → still allowed with substantiation.
Source: Directive (EU) 2024/825, Annex I and Guardian — EU bans misleading environmental claims.
Tier 1 — Quantified and Certified (Highest Defensibility)
Use these when you have third-party-certified lifecycle data.
| Compliant claim | Required evidence |
|---|---|
| "Product carbon footprint: 1.8 kg CO₂e per unit, verified by [auditor] per ISO 14067:2018" | ISO 14067 verification certificate with scope and boundary disclosed |
| "Scope 1+2 emissions reduced 42% between 2019 and 2025, verified by [auditor] per ISO 14064-1" | ISO 14064-1 verified GHG inventory |
| "Packaging certified C2C Gold by Cradle to Cradle Products Innovation Institute" | Valid C2C certificate number published on c2ccertified.org |
| "EU Ecolabel certified — license [number]" | Active EU Ecolabel license, verifiable on the European Commission Ecolabel database |
Tier 1 claims satisfy the ECGT substantiation test on day one because they reference a recognized certification or ISO standard that is verifiable from the claim itself.
Tier 2 — Methodology-Disclosed (Strong Defensibility)
Use these when you have internal carbon accounting audited by a recognized methodology but not by a third party.
| Compliant claim | Required evidence |
|---|---|
| "Scope 1+2 emissions cut 30% since 2020 baseline (GHG Protocol methodology)" | Publicly linked methodology page disclosing boundary, baseline year, calculation approach |
| "Reduced per-unit emissions by 22% through manufacturing efficiency (2021–2025)" | Linked technical note with production volume, energy mix, and calculation |
| "100% renewable electricity in our [specific factory or operation] since [date]" | Energy supply contract or Guarantee of Origin (GoO) certificate publicly referenced |
| "Product made from 85% post-consumer recycled PET" | Supplier chain-of-custody documentation, ideally RecyClass or GRS certified |
Tier 2 claims survive ECGT scrutiny when the linked methodology page is publicly accessible and dated within the last 24 months.
Tier 3 — Scope-Limited Transparency (Conditional Defensibility)
Use these when reductions are localized or partial.
| Compliant claim | Required evidence |
|---|---|
| "Our [specific product line] is designed to reduce emissions 15% compared to our previous generation (LCA methodology: PEF)" | Product Environmental Footprint study, publicly summarized |
| "Our office operations in [location] are powered by 100% renewable energy" | Explicit scope limitation to office operations, documented energy contract |
| "X% of our raw materials by weight come from recycled sources (2024 annual disclosure)" | Annual disclosure page with methodology and weight calculation |
| "Participating in [specific initiative] to reduce agricultural emissions on [X% of supply]" | Disclosed scope and partner organization; no extrapolation to whole company |
Tier 3 claims pass if and only if the scope limitation is communicated in the same sentence as the claim — not in a footnote or separate page.
Terms to Avoid Entirely
The following terms cannot be made ECGT-compliant without restructuring the underlying claim. The pragmatic choice for most businesses is to delete them from all marketing copy.
| Term | Why it fails | Replace with |
|---|---|---|
| "Carbon neutral" (product) | Annex I point 4d ban when based on offsets | Disclosed reduction + separate offset disclosure |
| "Climate neutral" (product) | Same as above | Specific reduction percentage with methodology |
| "Net zero" (without plan) | Annex I point 4f ban on future-performance claims | Interim target + public transition plan |
| "Climate positive" | No defined standard; vague | Specific measurable outcome |
| "Eco-friendly" / "green" | Generic environmental claims (Annex I point 4a) | Substantiated specific claim |
| "100% natural" | Undefined; misleading if includes processing | Ingredient list + "X% of ingredients from [defined source]" |
| "Biodegradable" (unqualified) | Banned without condition, timeframe, and environment specification | "Certified industrially compostable per EN 13432 — breaks down within 12 weeks in industrial composting" |
| "Compostable at home" | Needs TÜV AUSTRIA OK compost HOME or equivalent | Certification number explicitly cited |
Rewrite Template
For every existing environmental claim, apply this template:
- Specific action (what was done)
- Quantified outcome (by how much)
- Baseline (compared to what)
- Methodology (how it was measured)
- Verification (who validated it)
Example applied to a real case:
- Before (banned): "Our deliveries are carbon neutral."
- After (compliant): "We cut delivery emissions 38% between 2020 and 2025 by shifting to electric vans (Scope 1 data, verified by [auditor] per ISO 14064-1). Residual emissions are offset through Gold Standard certified projects; see breakdown at /climate."
The after-version is longer, but the length is what makes it compliant: the claim itself contains the evidence the ECGT requires.
Find Every Banned Term on Your Site
Our free scanner flags "carbon neutral," "net zero," and every other ECGT-banned term on any URL in under 60 seconds.
Free Greenwashing ScanFrequently Asked Questions
Is every carbon neutral claim banned?
No. Claims of carbon neutrality achieved through actual value-chain emission cuts (not primarily offsets) remain permissible when substantiated. The ban targets offset-based neutrality claims specifically — Annex I point 4d of the amended UCPD.
Can I still offset residual emissions?
Yes — but offsets cannot be the primary basis for a neutrality claim about a product. Offsets may be disclosed separately alongside actual reduction figures.
What about the term net zero?
"Net zero" as a future-tense claim must comply with Annex I point 4f: clear, objective, publicly available commitments; an implementation plan; and third-party monitoring. Without all three, the term cannot be used in consumer-facing communication.
What certifications replace self-issued neutrality claims?
ISO 14067 (product carbon footprint), ISO 14064-1 (organizational GHG inventory), EU Ecolabel, Cradle to Cradle, Climate Label Certification 2026 standard. Each has publicly verifiable certificate databases.
Does the ban apply to company-level neutrality claims?
The primary ban (Annex I point 4d) is product-level. Company-level claims face separate scrutiny under the future-performance rules of point 4f and under CSRD / ESRS E1 disclosure requirements.
Bottom Line
"Carbon neutral" and "climate neutral" product claims based on offsets are banned from 27 September 2026. The replacement language is longer but more defensible: state the actual reduction, the methodology, the verification, and disclose residual offsets separately. Use our free scanner to find every banned neutrality term on your site before the deadline.