Businesses selling to EU consumers should review the climate claims customers see alongside the evidence behind their carbon-credit purchases. The EU application date for Directive (EU) 2024/825 was 27 September 2026. Its changes to consumer law make the relationship between a product claim and the activity supporting it especially important.
For a sustainability team, the practical question is straightforward: does the evidence support the precise message a customer receives? A credible project can still be attached to an unsuitable claim. Procurement and communications therefore need a shared review process, with legal advice on the rules applying in each market.
Understand the specific prohibition
The Directive prohibits claims, based on greenhouse-gas offsetting, that a product has a neutral, reduced or positive greenhouse-gas impact. Buying more credits or selecting a stronger project does not resolve that particular problem. Teams should review the proposed claim before committing to a purchasing strategy built around it.
The Commission services' September 2026 Q&A distinguishes product claims from company-level claims, which remain subject to other consumer-law provisions. It also explains that businesses can communicate transparently about investments in environmental initiatives, including carbon-credit projects, provided the communication is not misleading. That is a useful distinction when planning a climate contribution, but it is not automatic approval of a particular sentence.
Start with what the customer sees
Create a short inventory of current claims. Include product pages, packaging, paid advertisements, retailer descriptions and sales materials. Record the exact wording and retain the surrounding layout. A qualification in a separate technical report may not convey what the main message implies.
For each claim, answer four questions:
- What is being described: a product, one component, a service, the business or a financed project?
- What happened: an operational improvement, a credit purchase, a retirement or an intended future activity?
- What period and boundary does the statement cover?
- Which document supports each material part of the statement?
This exercise often exposes a practical mismatch. The procurement file may establish that a company purchased credits, while the campaign describes a product as having no climate impact. Resolving the mismatch requires reviewing the claim itself, not simply adding another document to the file.
Build two connected evidence records
Keep the evidence for the company's own emissions performance distinct from the evidence for its external climate contribution. Connect them through the approved communication, without allowing one record to stand in for the other.
For a statement about an actual emissions reduction, the review file should explain the measured activity, comparison period, calculation method and relevant boundaries. Document any important changes in assumptions. A percentage without a clear baseline can be difficult for a reader to interpret and difficult for the company to defend.
For a statement about a carbon-credit purchase, ask for the project identifier, programme and methodology, relevant monitoring period, verification documentation, quantity and transaction status. If the communication concerns retired credits, retain the registry retirement record and identify the beneficiary. For a forward purchase, describe the commitment as forward-looking and explain the delivery conditions; do not present expected delivery as an accomplished outcome.
These are recommended review controls. The evidence needed for a particular claim will depend on its wording, context and applicable law.
Give the review a clear owner
A useful claim record can fit on one page: proposed wording, intended audience, geographic markets, supporting evidence, unresolved questions and approval date. Assign responsibility for each open question before publication.
Sustainability colleagues should confirm the technical boundaries. Procurement should confirm what the contract and registry records establish. Communications should check the complete customer-facing presentation. Legal counsel should assess the intended use in the relevant markets. Repeat that review when the wording, underlying evidence or intended audience changes.
A contribution statement should describe the activity accurately and proportionately. Where supported, it might explain that the company financed a named project or retired a specified quantity of credits. It should not imply a different product characteristic. The exact wording still needs review, including any images, labels and qualifications presented with it.
Make the next decision before the next campaign
Start with the most visible claims and those connected to current sales. Decide which can remain, which need clearer boundaries and which should be withdrawn or replaced. Keep a dated record of the decision and the evidence used.
The September application date makes this a current operational task. It also creates an opportunity to connect climate procurement more closely with honest, useful communication. Planning a carbon-credit purchase or project? Start a conversation with Súrefni about the evidence your decision needs.
This article provides general information about EU consumer-facing marketing. Businesses should obtain advice on national implementing rules and specific claims. Applicability in Iceland should be assessed separately.
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