Carbon neutral claims Ireland’s consumer brands built on offsets are now unlawful. The European Union (Empowering Consumers for the Green Transition) Regulations 2026 apply from 27 September 2026, according to the Competition and Consumer Protection Commission (CCPC). They amend the Consumer Protection Act 2007 and the Consumer Rights Act 2022 to implement the EU Empowering Consumers for the Green Transition (ECGT) Directive.
The core change is simple. A product can no longer be marketed as neutral, reduced or positive in climate impact because its emissions were offset. There is no grace period for existing packaging or campaigns.
Carbon neutral claims Ireland's brands built on offsets are now banned
The ECGT Directive adds offset-based claims to the list of banned commercial practices. A claim of neutral, reduced or positive impact is only allowed where it rests on the product’s actual life cycle impact, not on credits bought outside its value chain.
A carbon neutral badge bought with offsets is now a prohibited commercial practice. The European Commission found that more than 50% of green claims made by EU companies were vague or misleading, and 40% were unsubstantiated. These rules are its response.
Four claim types now need a check
The rules sort environmental marketing into four groups. Each one needs a different test before it stays on pack or online.
- Offset-based product claims (“carbon neutral”, “climate positive”): banned unless based on actual life cycle impact.
- Generic claims (“eco-friendly”, “green”): banned unless the trader can show recognised excellent environmental performance, such as the EU Ecolabel or an officially recognised EN ISO 14024 scheme.
- Sustainability labels: only allowed if based on a certification scheme with independent third-party monitoring, or set by a public authority. Self-declared marks are out.
- Future performance claims (“net zero by 2040”): allowed only with a detailed, realistic, public implementation plan with measurable, time-bound targets, checked by an independent expert.
Consumer-facing brands carry the exposure
The Irish Consumer Protection Act applies to business-to-consumer dealings. It defines a consumer as a natural person acting mainly outside their trade or profession. A dairy co-op selling butter in Irish supermarkets is directly in scope. A contract manufacturer selling only to other businesses is typically not, although its customers may now ask it for evidence.
That second effect matters. Brand owners that need life cycle data for their own claims will push the request down the supply chain. Suppliers that can provide product carbon footprints on request can win business. See our approach to supply chain and Scope 3 data.
A net zero pledge now needs a plan behind it
Forward-looking claims are not banned, but they must be backed by a plan. The European Commission’s guidance suggests independent verification every one or two years, with extra checks after material changes.
For most sites, this means a costed decarbonization plan with Scope 1, 2 and 3 baselines, interim targets and allocated resources. A slogan on a website is no longer enough. Our advisory team builds these plans to a standard an independent verifier can test.
Audit every live claim this quarter
Start with an inventory. List every environmental word, logo and target on packaging, websites, adverts and tenders aimed at consumers. Mark each one against the four groups above.
Remove or reword any offset-based claim now. Replace generic terms with specific, measured facts, such as a verified percentage cut in product emissions. For net zero pledges, check that a public plan exists and that someone independent has reviewed it. Food, dairy and beverage brands should put this first. Contact us to scope a product footprint or plan review.
Offsets no longer support a neutral or positive claim, and generic green language needs recognised proof. Net zero pledges survive only with a public, independently checked plan.
