Guide · UCPD Annex I, point 4c

Why “carbon neutral” claims become illegal in the EU

Updated 10 August 2026 · 5-minute read

Most of the directive’s new rules ban vague claims but leave a path to keep them with better evidence. Point 4c is different: from 27 September 2026 it bans claims that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions when the claim is based on the offsetting of those emissions. There is no substantiation path. The quality of the offsets is irrelevant — the claim itself is on the blacklist.

What the ban covers

Any product-level climate claim that leans on offsets, in any wording:

• “carbon neutral”, “CO2 neutral”, “climate neutral”
• “climate positive”, “carbon positive”, “carbon negative”
• “CO2 compensated”, “100% offset”
• “net zero” applied to a product
• “we plant a tree, so this order is climate neutral” — the tie between the purchase and the neutrality is exactly the banned construction

In practice, nearly every “carbon neutral product” claim on the market is offset-based — genuinely eliminating all life-cycle emissions of a physical product is rare. That’s why the practical advice for merchants is short: treat these phrases as gone.

Why the EU banned them outright

The directive’s reasoning (Recital 12): offset-based neutrality claims make consumers believe the product itself, or buying it, has no climate impact. The product’s emissions still happen; a credit purchased elsewhere doesn’t change them, offset projects vary wildly in integrity, and the equivalence the claim asserts can’t be verified at the till. Rather than police offset quality claim by claim, the EU removed the construction.

Courts were already heading there: in 2024 Germany’s Federal Court of Justice (BGH, klimaneutral) held that ambiguous “climate neutral” advertising is misleading unless the ad itself explains that neutrality rests on compensation. The directive goes one step further — from September 2026, the explanation doesn’t save it either.

What you can still say

Real reductions, stated specifically

The ban targets offset-based claims. A claim that reflects actual life-cycle emission reductions in your own operations and value chain is outside point 4c — but it must be specific and evidenced, or it collides with the generic-claim rule (point 4a) instead:

Honest statements about funding climate projects

Supporting climate projects is legal; claiming the product is neutral because of it is not. “We contribute 1% of revenue to verified reforestation projects” describes what you do without asserting a product impact. Keep the two ideas apart on the page — the closer the funding statement sits to a neutrality implication, the closer you drift back to 4c. Treat this as review-recommended territory rather than a safe harbour.

Future targets — with a real plan

“Net zero by 2030” is a future-performance claim governed by Art 6(2)(d): it’s misleading unless backed by clear, objective, publicly available and verifiable commitments in a detailed and realistic implementation plan with measurable, time-bound targets and independent third-party monitoring. If the brand doesn’t publish an audited transition plan, the target doesn’t belong on a product page.

What to do this week

1. Search your store for the phrase list above — titles, descriptions, collections, pages, blog posts, and image alt text.
2. Remove or rewrite every offset-based claim; they carry the highest enforcement risk of anything in the directive.
3. If you fund offset projects, reframe the copy as a factual funding statement, separated from any product-impact language.
4. Check your suppliers’ marketing material before importing it into your product pages — the claim becomes yours when you publish it.