Carbon neutral products?

Carbon neutrality, according to the United Nations Intergovernmental Panel on Climate Change (IPCC), refers to a state in which human activities have no net impact on the climate. The international standard ISO 14068-1 specifies this at the product level: a product's carbon footprint must first be reduced, and only remaining emissions may then be "offset."

Unlike a company's Corporate Carbon Footprint (CCF), the Product Carbon Footprint (PCF) refers to a specific product unit or SKU and captures all emissions along the value chain.

Carbon neutrality never means "emission-free," but rather a net zero balance of reduction and offsetting.

Carbon neutrality under EmpCo

The term "carbon neutral products" is no longer permissible under the EU directive Empowering Consumers for the Green Transition (EmpCo) if it is based solely on the financing of climate projects.

The EmpCo directive protects consumers from misleading environmental claims and labels. The new regulations will be binding for all companies advertising in the EU from 27 September 2026.

Under the EmpCo directive, stricter rules apply:

Proof of reduction required: Carbon neutrality claims are only permissible if they are based on reductions actually achieved across the entire value chain.

Offsetting alone is not enough: Compensation through climate projects is no longer sufficient as the basis for a carbon neutrality claim.

High bar in practice: A "carbon neutral" claim requires near zero emissions business operations, which is not realistic for most companies.

Companies that continue to advertise "carbon neutral products" without disclosing concrete proof of reductions risk formal warnings, injunctions, and reputational damage.

"Carbon neutral" will effectively no longer be usable on products from September 2026 unless the entire product lifecycle is nearly emission-free.