If your packaging, website or tender documents make carbon neutral claims about a product, the European Commission’s decision this month changes less than the headlines suggest. On 4 November 2026 the Commission formally withdrew the Green Claims Directive, the proposal that would have required independent verification of voluntary environmental claims.
The rules that already bite were left untouched. Ireland’s Empowering Consumers for the Green Transition Regulations have applied since 27 September 2026, and the Competition and Consumer Protection Commission (CCPC) guidance is clear that they cover every trader selling to EU consumers, in store or online.
The withdrawn directive was the future, not the present
Withdrawing the Green Claims Directive removed a future rulebook, not the one already in force. The Irish Regulations, S.I. No. 124 of 2026, transpose the EU Empowering Consumers directive into the Consumer Protection Act 2007 and the Consumer Rights Act 2022. That means a misleading environmental claim is now a consumer protection matter in Ireland, with the CCPC as the enforcer and, under the 2023 representative actions law, the possibility of collective claims from qualified entities.
Which carbon neutral claims no longer work
The sharpest change is for claims built on offsets. A claim that a product has a neutral, reduced or positive greenhouse gas impact is banned where it rests on carbon offsetting. A dairy pack that says “carbon neutral” because the processor bought credits is the textbook case.
Generic wording is also caught. “Green”, “eco-friendly” and similar terms are banned unless the trader can show recognised excellent environmental performance, such as an EU Ecolabel. A claim about a whole product or business that is true of only one aspect is out, and so is any sustainability label not backed by a certification scheme or a public body.
A practical check of your carbon neutral claims
Most sites can typically work through this with their marketing, sales and sustainability leads in one sitting:
- List every environmental claim in use: packaging, website, sales decks, tender responses and product data sheets.
- Mark each claim that depends on offsets. These are the first to remove or rewrite.
- For each remaining claim, find the evidence behind it. A product carbon footprint with stated boundaries and data sources is what a regulator, retailer or customer will typically ask for.
- Check any future claim, such as a net zero year, against a written plan. Future performance claims are only permitted where they rest on clear, verifiable commitments in a detailed and realistic implementation plan.
- Ask your customers what they now need from you. Retail and brand customers selling to consumers may push the same evidence request down their supply chain, even to sites that never sell direct.
Replace offset claims with measured reductions
The safest claim is the one you can measure. A site that has cut gas use through heat recovery, or moved process heat to a heat pump, can state the reduction in tCO2e against a defined baseline and defend it. That is a stronger story for a retailer’s buyer than a neutrality badge, and it holds up if the CCPC asks. If your claims rest on a footprint that has not been refreshed in years, rebuilding it to a clear Scope 1, 2 and 3 boundary is the place to start, and a costed decarbonisation plan is what turns a net zero target into a claim you are allowed to make. Food and drink processors carry the most exposure, given how much of their output carries a consumer label; our food, dairy and beverage page sets out how we work with them.
Offset-based neutrality claims on products are banned in Ireland, and generic green wording needs recognised proof. Sites that can show measured reductions against a baseline will keep the claims their customers want to see.
