From 27 September 2026, environmental claims based on offsetting can no longer be used in the European Union. That means “carbon neutral”, “climate neutral”, “CO₂ neutral”, “net zero emissions”, “plastic neutral”, “plastic positive” and any variant asserting that a product has a neutral, reduced or positive environmental impact because the company offsets its emissions or its plastic footprint.
This is not a matter of qualifying such claims or adding small print. They are prohibited in all circumstances, as part of the blacklist of unfair commercial practices. And unlike other obligations, this one reaches what is already printed: packaging, labels, catalogues and promotional material already in circulation.
What the rule actually prohibits
Directive (EU) 2024/825 adds a specific practice to the blacklist of the Unfair Commercial Practices Directive: claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment.
Three points worth understanding:
It does not prohibit offsetting. A company may continue investing in removal or reduction projects. What it may not do is pass that offsetting on to the consumer as a claim about the product.
It does not prohibit talking about offsetting. A company may inform about its offsetting investments, provided they are presented separately from the product’s characteristics and do not suggest the product itself is neutral.
It reaches the whole family of expressions. The prohibition looks at substance, not literal wording: “climate positive”, “net zero product”, “zero footprint”, green-leaf icons paired with “offset”, or neutrality labels based on credits all fall within it, even without the words “carbon neutral”.
The legislator’s logic is simple: a consumer reading “carbon neutral” understands that the product generated no emissions — not that it generated them and the company bought credits elsewhere. And the studies underpinning the Directive showed that a substantial share of those credits did not represent real, additional or permanent reductions.
What can be said instead
Here is the useful part: the rule does not prevent communicating environmental effort. It prevents communicating it through an outcome label that is not true. What does work:
Concrete, verifiable data about the product. Instead of “carbon neutral product”: “We have reduced this product’s manufacturing emissions by 34% since 2020 (from 12.1 to 8.0 kg CO₂e per unit; methodology and verification at [link]).” Less striking, far more credible, and legally safe.
Offsetting described for what it is, and kept separate from the product. “In addition to reducing our emissions, we invest in certified removal projects: in 2025 we allocated €X to [project]. This investment does not offset or cancel this product’s emissions.” That last sentence is what protects the claim.
Targets, presented as targets. “Our goal is to cut supply-chain emissions by 50% by 2030” — with a public implementation plan verified by an independent third party, which is what the Directive requires for a future environmental performance claim to be admissible. Without that plan, the target itself becomes a prohibited claim.
Specific, demonstrable attributes. Recycled content with its exact percentage, reparability, durability, returnable packaging. The concrete always holds up better than the global.
The practical rule for the marketing team fits in one line: claim what you have done, not the outcome you have purchased.
And the particular case of “plastic neutral”
The wording of the rule refers to greenhouse gas emissions, which leads some companies to ask whether plastic neutrality claims fall outside it. The prudent answer is that they do not.
Two reasons. First, even if they did not fit that specific blacklisted practice, they remain subject to the general prohibition on misleading practices: claiming “plastic neutral” where the product contains virgin plastic and what exists is a waste-collection contract on another continent is, quite simply, a claim liable to mislead as to the product’s characteristics. And there the analysis is case by case, without the certainty of an express prohibition — which is worse, not better. Second, the Directive also tightens the regime for generic environmental claims, and “plastic neutral” without recognised excellent environmental performance falls squarely within that other prohibition.
Recommendation: treat them exactly like carbon claims and replace them with concrete data (percentage of recycled plastic, grams of plastic avoided per unit, packaging return scheme).
What to do before 27 September
The complication here, compared with the labels rule, is that it affects physical materials already produced. A realistic plan:
- Locate every occurrence: packaging and labels (including warehouse stock and goods already in the channel), website and product pages, marketplaces, catalogues, advertising, email signatures, sales decks and social profiles.
- Prioritise by consumer exposure: digital first (changed in hours), then promotional material, with the packaging decision running in parallel.
- Decide on physical stock: relabelling, cover stickers, or sell-through on a documented timetable. The Directive provides no general transitional regime for goods already manufactured, so any leeway depends on the consumer authority’s discretion — and that discretion will be far kinder to a company showing a dated plan than to one that did nothing.
- Rewrite the message, not just delete it: replace the label with the concrete figure and make its methodology accessible.
- Review contracts with offsetting providers: many include licences to use neutrality labels and logos that can no longer be displayed. Check what usage obligations and warranties were agreed.
- Document the whole process: the adaptation file is the first line of defence in an inspection or against a competitor’s claim.
The risk, concretely
As a blacklisted practice, the authority need not prove that consumers were actually misled: the conduct is unfair in itself. Two fronts open up — the administrative one, with consumer authority penalties that for widespread cross-border infringements can reach 4% of annual turnover, and the civil one, through the actions available under the Unfair Competition Act to any competitor.
And there is a third, less discussed but real: neutrality claims tend to appear in public tenders, ESG questionnaires and non-financial reporting. A claim that ceases to be lawful on 27 September and still appears in contractual or corporate documentation can carry consequences well beyond consumer law.
How we can help
At Ferrer-Bonsoms Abogados we audit your company’s environmental claims against Directive 2024/825 and Spanish law, draft the replacement wording with its supporting documentation, and prepare the adaptation file that evidences the company’s diligence.
This article is part of our series on greenwashing and environmental communication. Previous articles: Greenwashing: what changes on 27 September 2026 · Sustainability labels and certification marks. Next article: the Spanish Sustainable Consumption Act — status and what to anticipate.