Short answer: no, not if the claim rests on offsetting.
From 27 September 2026, Directive (EU) 2024/825 (the "EmpCo" Directive) bans claims that a product or company is carbon neutral, climate neutral, or net zero on the basis of purchased offsets. It also bans generic claims like "environmentally friendly" or "green" where the benefit is not demonstrated. There is no transition period, and the rules apply to marketing already live on 27 September, not only to new campaigns.
What survives is narrower and more useful: specific claims about one clearly named aspect, backed by evidence.
What exactly is banned
The Directive amends the Unfair Commercial Practices Directive and adds the prohibited practices to its blacklist. Three things change for B2C communication.
Offset-based neutrality claims are gone. Any claim that a product has neutral, reduced, or positive climate impact because emissions were compensated is prohibited. This is the change with the widest reach, because it invalidates a claim structure that a great many brands built their sustainability messaging on. The offsetting itself is not illegal. Saying it makes your product neutral is.
Generic environmental claims without proof are gone. "Eco-friendly", "green", "conscious", "kind to the planet" and similar terms cannot be used unless you can demonstrate recognised excellent environmental performance relevant to the claim.
Unverified future commitments are gone. A public target such as "climate neutral by 2030" now requires a detailed, realistic implementation plan with allocated budget, plus independent third-party verification and monitoring. A target announced without that backing is a prohibited practice.
Why this lands differently than CSRD did
Sustainability reporting rules got lighter in 2025. The Omnibus package narrowed the CSRD to companies above 1,000 employees and €450 million turnover, taking many mid-sized businesses out of scope entirely.
Advertising rules moved the other way. The obligation to report shrank; the obligation to be accurate in public did not. The result is that a company can be out of scope for CSRD and still fully exposed under EmpCo, because EmpCo does not care about your size. It cares about what you put on a package, a website, or a LinkedIn post.
The enforcement route is different too. Reporting failures surface at audit. Claims failures surface when a competitor complains, a regulator opens a case, or a customer challenges you publicly.
What you can still say
The permitted claim is specific, evidenced, and about something you actually did.
- Instead of: "Carbon neutral product"
Say: "Product footprint reduced 34% since 2022, verified against ISO 14067" - Instead of: "Climate neutral company"
Say: "Scope 1 and 2 emissions down 41% since 2021; remaining emissions disclosed" - Instead of: "Eco-friendly packaging"
Say: "Packaging is 92% recycled cardboard, recyclable in Dutch kerbside collection" - Instead of: "We offset our shipping"
Say: "We fund [project]. This is additional to our reduction target, not a substitute"
The pattern is the same each time. Name the aspect, quantify it, state the method, and keep the evidence available. A claim you can defend with a calculation is a claim you can keep.
Note the last row. You may continue to describe climate contributions, provided you do not present them as making anything neutral. Framing matters: it is a contribution alongside reduction, not a cancellation of your footprint.
What to do before the date
Inventory every live claim. Website, packaging, product pages, sales decks, email footers, trade show stands, social profiles. Most organisations underestimate this by a wide margin, because claims accumulate in places marketing no longer controls.
Sort each claim into keep, fix, or remove. Keep the specific and evidenced. Fix the ones where the underlying performance is real but the wording is generic. Remove anything that depends on offsetting for its meaning.
Find the evidence for whatever you keep. A claim about a product needs a footprint behind it. If you claim a reduction, you need a defensible baseline and a current figure calculated the same way. This is where most claim audits stall, and it is the reason to start now rather than in September.
Fix the forward-looking targets. If you publish a 2030 or 2040 commitment, it needs a plan with real numbers and independent verification. An unbacked target is now a prohibited practice rather than an aspiration.
Where the data comes from
Every surviving claim needs a number underneath it, and the number needs a method someone else could reproduce.
For product-level claims, that means a life cycle assessment or a product carbon footprint calculated to a recognised standard. For claims about your organisation, it means a corporate carbon footprint covering the scopes you reference. For construction products sold into Dutch tenders, an EPD already gives you verified data in the format the market expects.
For reduction claims specifically, the baseline is what gets challenged. You need the original year calculated on the same boundary as the current year, which is exactly what breaks when a company recalculates its footprint in a new tool without carrying the history across. Keeping the series consistent year over year is the point of measuring on a platform rather than rebuilding a spreadsheet each cycle.
The deadline is the easy part
27 September 2026 is fixed and public. The harder question is whether the numbers behind your claims survive contact with someone who wants to disprove them, because that is the test the Directive actually sets.
If your sustainability messaging currently leans on offsetting, the work is not a rewrite. It is a reduction story you need to be able to evidence, and that starts with knowing your footprint properly.
Sources: Directive (EU) 2024/825, European Commission guidance on the Unfair Commercial Practices Directive.
