“Carbon neutral product” based on purchased external credits: covered by the prohibition on offset-based product claims.
BuVNK · EmpCo & climate claims · Updated 14 October 2026
Climate-neutral and CO₂-neutral claims: What changed in 2026?
A practical guide to climate-related marketing: product claims, carbon offsets, actual emission reductions and future targets, based on EU rules and German consumer law.
Applies since 27 Sep 2026Consumer-facing claimsOffsets ≠ product reductions
Important: Since 27 September 2026, Germany has applied the EmpCo-related amendments to its unfair competition law (UWG). Product climate-impact claims based on offsetting are expressly prohibited. Other climate-related claims still require separate assessments of accuracy, clarity and evidence. General guidance, not individual legal advice.
01 / Regulation
Which product climate claims are expressly prohibited?
Item 4c of the annex to the German UWG lists a practice that is always prohibited towards consumers: based on greenhouse-gas offsetting, a trader claims that a product has a neutral, reduced or positive environmental impact in terms of greenhouse-gas emissions.
Prohibited: offsets presented as product neutrality
Example: “This parcel is climate neutral” when that claim is based solely on buying carbon credits outside the product value chain.
Not automatically prohibited: actual measured reductions
A precise, evidenced statement about emissions reduced within a product’s value chain may require a different assessment. It still needs a clear baseline, sound data and no misleading implications.
Different assessment: company-level statements
The specific prohibition on offset-based product neutrality does not automatically extend to every statement about a company. Company-wide neutrality claims may nevertheless breach other misleading-advertising rules.
02 / Claim typesProduct + offsetsExpress prohibition / high risk Product + actual reductionsCase-specific review Entire companyOther rules still apply Future targetPlan and external verification
Four claim types – four different reviews
The words “climate neutral” are not a compliance certificate. What matters is what the claim covers and how it is substantiated.
“18% less CO₂e in production than in 2023”: source data, system boundaries, timing and a comparable baseline must be verifiable.
“We are climate neutral” calls for a careful review of organisational boundaries, emissions accounting, real reduction and any offsetting. The product-specific ban does not settle the case.
“Climate-neutral by 2035” needs clear public commitments, realistic action, time-bound measurable objectives and the required independent external review.
03 / Practical wording
How to make climate-related wording more specific
The examples illustrate more precise wording, not pre-approved legal templates. Each statement must be checked against actual facts, evidence and the complete advertisement.
Instead of simply “climate neutral”
“Manufacturing emissions recorded for 2025 were X kg CO₂e, using method Y.”
Disclose the boundary, methodology and verification status; a figure alone does not establish an environmental benefit.
Instead of “100% climate friendly”
“This facility used X% less electricity in 2025 than in 2023.”
Use only where comparable meter data supports the number. Lower energy use is not the same as climate neutrality.
Instead of “carbon-free through tree planting”
“We separately support a forest conservation project; this does not make the product climate neutral.”
Explain additional climate funding without attributing a neutral product impact to it.
04 / Evidence
Which evidence makes a climate claim credible?
Reliable climate communication starts with a documented impact – not with a marketing slogan.
Scope
Does the claim cover a product, component, service, site or the entire business?
Measurement
Record which gases and CO₂ equivalents were measured and which lifecycle stages and emission sources are included.
Comparison and dates
For reduction claims, document the baseline year, metric, method and comparability.
Reduction versus offsetting
Separate actual reductions within the value chain from financing external projects or purchasing carbon credits.
Message and evidence
Review not just the number: graphics, seals, headlines and footnotes may create a misleading overall impression.
Approval and updates
Record the source date, responsible approvers, evidence version and review cycle.
05 / Checklist
Six questions for marketing and compliance teams
01Does the advertisement present a specific product as “climate neutral” or “carbon neutral”?
02Is any claimed neutral, reduced or positive product impact based, even partly, on greenhouse-gas offsetting?
03Are the emission sources, units, time period and lifecycle boundaries clearly defined?
04Did claimed reductions actually occur within the product value chain and are they supported by data?
05Are direct emissions reductions distinguished clearly from funding external climate action?
06Are future targets supported by an objective plan, measurable goals and independent verification?
Each question requires reviewing the complete claim and supporting records.
06 / FAQ
Frequently asked questions on climate neutrality claims
Is using the phrase “climate neutral” always banned?
No. The particular absolute prohibition targets product impact claims based on greenhouse-gas offsetting. Other types of claims must comply with general and other specific legal rules.
May a company still mention carbon offsets?
A factual and non-misleading statement about contributing to separate climate projects is different from claiming that offsets make a product climate neutral. The overall presentation matters.
Is a carbon footprint report sufficient evidence?
It may form an important part of substantiation, but the wording, boundaries, methodology, time period, comparator and overall impression also matter.
May businesses advertise real emissions reductions?
Potentially, if the claim is precise, relevant, supported and non-misleading. There is no blanket approval for any particular phrase.
Are services covered too?
Yes. Relevant EU consumer law treats goods and services as products for these purposes. The commercial context and intended consumer audience remain important.
BuVNK / EmpCo
More EmpCo and BuVNK information
07 / Official references
Legislation and official guidance
BuVNK · EmpCo
Make climate communication clearer and verifiable
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