Since 27 September 2026, “carbon neutral” is gone from the vocabulary of any company that buys carbon credits and talks to consumers in the EU. Most of those companies did not stop buying credits. They stopped knowing what to say about them.
The answer is the contribution claim. It is the one way of talking about carbon credits that EmpCo explicitly leaves open, and done well it is more convincing than the claim it replaces, because it is specific and checkable.
This guide covers the legal basis, the four elements of a solid contribution claim, ready-to-use wording for each channel, the words to drop, and the evidence each claim needs. For the full picture of what is banned, see our guide to carbon neutral claims under EmpCo.
The short answer. A contribution claim says what you financed and stops there: “In 2026 we financed 2,000 tonnes of verified emission reductions from [project] in [country], certified under [standard]. This does not reduce our own emissions.” It avoids “neutral”, “compensated” and “offset” in any claiming sense, stays separate from claims about a product’s footprint, and is backed by retirement evidence you can show.
What a contribution claim is, and why it is allowed
EmpCo bans claims that a product has a neutral, reduced or positive impact on greenhouse gas emissions because of offsetting (Annex I point 4c), and generic claims such as “climate neutral company” without recognised excellent environmental performance (point 4a). The same directive deliberately leaves room for something else. Recital 12 says the ban “should not prevent companies from advertising their investments in environmental initiatives, including carbon credit projects, as long as they provide such information in a way that is not misleading”.
The European Commission’s Q&A on the directive repeats it: the prohibition “does not prevent companies from communicating about their investments in environmental initiatives, including carbon credit projects, provided this information is presented transparently and is not misleading”.
That is the difference between the two kinds of claim:
Compensation claim | Contribution claim | |
|---|---|---|
What it says | Our emissions, or this product’s emissions, are cancelled out | We financed this climate project, this much |
Example | “This delivery is carbon neutral” | “For every delivery we fund 2 kg of verified emission reductions” |
Under EmpCo, towards consumers | Banned for products (4c) and as a generic company claim (4a) | Allowed if transparent and not misleading |
Standard-setters moved the same way before the law did. Gold Standard has encouraged buyers to shift away from “carbon offsetting” and “carbon neutral” claims towards new ways of describing what their credits do, and SBTi’s Net-Zero Standard V2.0 uses the term “climate contributions” for credits bought on top of reductions.
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The four elements of a solid contribution claim
A contribution claim holds up when it does four things.
Says what you financed, with a number. Tonnes of verified emission reductions or removals, or an amount in euros. “We support climate projects” is not wrong, but it is so vague that it invites the question of what you are hiding.
Names the project. Project type, country and the standard it is certified under. Name the project itself where you can.
Says what it does not do. One sentence that the credits do not reduce your own emissions, or those of the product. This sentence is what keeps the claim on the right side of point 4c.
Points to the evidence. A link to a page with the registry retirement, so a reader can check the tonnes are real and retired in your name.
A fifth element strengthens the claim without being required: your own reduction effort next to it. “We cut our emissions by 18% since 2022 and finance verified projects for part of what remains” is a stronger story than the credits alone, as long as the two numbers stay separate.
Wording that works, channel by channel
The same claim needs different wording depending on where it appears and who reads it. The examples below use placeholder figures; replace them with your own.
Sustainability page or annual report
This is the place for the full claim, with numbers and context.
“In 2026 we financed 2,000 tonnes of verified emission reductions from clean cookstove projects in Malawi and 300 tonnes of verified CO2 removals from biochar production in Germany, certified under Gold Standard and Puro.earth. The credits are retired in our name; see the registry records below. They do not reduce our own emissions, which fell by 18% compared with 2022.”
Product page or packaging
This is where the risk is highest, because point 4c is about products. A per-product contribution is possible if it does not suggest that the product’s impact is cancelled. Keep it away from any statement about the product’s footprint, and always include the “does not reduce” sentence.
“For every order, we fund 2 kg of verified emission reductions from clean cookstove projects in Malawi. This does not reduce the emissions of your order. How it works: [link].”
Avoid a leaf icon, a green tick or the word “neutral” anywhere near it. Some companies decide to move all credit communication off the product and onto the sustainability page. That is the most cautious choice.
Proposals and tenders (business customers)
EmpCo’s bans apply to consumer communication, but proposals still fall under the rules against misleading advertising, and procurement teams increasingly ask for the evidence.
“[Your company] reduces its own emissions through [measures] and, in addition, finances verified climate projects. In 2026 we retired 5,000 tonnes of Gold Standard credits from [project type] in [country] in our name. We can provide the registry records on request.”
If a customer asks you to state that your service is carbon neutral in their supplier questionnaire, answer with the facts instead: emissions per unit, reduction plan and credits retired.
LinkedIn, press releases and campaigns
Short channels tempt short claims. A public post can reach consumers, so treat it as consumer communication.
“This year we financed 300 tonnes of verified CO2 removals from biochar production. They don’t reduce our own emissions, which we are cutting by 40% by 2030. More on the projects and the registry records: [link].”
Email signatures, invoices and event materials
These are where old claims survive longest. “This email is carbon neutral” and “Climate neutral event” both fall under the ban if consumers can see them. Either remove the line or replace it with a link to your sustainability page: “How we take climate responsibility: [link].”
Words to drop, and what to say instead
Drop | Why | Say instead |
|---|---|---|
Carbon neutral, climate neutral, CO2 neutral | Banned for products (4c) and as a generic company claim (4a) | “We finance verified climate projects” with numbers |
Compensated, offset (as a claim) | Suggests your emissions are cancelled | “We fund”, “we finance”, “we support” |
Climate positive, net positive | Banned on the same basis | Drop it; say what you financed |
Net zero (without a plan) | Future claims need a public, verified plan | “Our target is net zero by [year]; read our plan [link]” |
“Removes your footprint” | Suggests a cancelled impact | “Finances CO2 removals equal to [x] tonnes” |
Own label or logo saying “neutral” | Own labels without certification are banned (2a); the claim is banned too | No label; a link to the facts |
Using “offset” to describe the market in a neutral sense, as in “the voluntary carbon market, sometimes called the offset market”, is not a claim. The risk lies in saying that something is offset.
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Removals and avoidance credits need different wording
Precision about credit type is part of not misleading. Call removals removals and reductions reductions.
Avoidance and reduction credits, such as cookstoves or renewable energy: “verified emission reductions”. Do not describe them as taking CO2 out of the air.
Removal credits, such as reforestation, biochar or direct air capture: “verified CO2 removals”, with the storage type if you can, for example “stored in biochar” or “stored in trees”. For removals that store carbon for a limited time, avoid “permanent”.
If you buy both, report them separately. A reader who learns later that most of your “removals” were avoidance credits will doubt everything else you said. Our avoidance vs removal guide explains the difference in more detail.
Contribution claims in euros
A contribution does not have to be expressed in tonnes. SBTi’s Net-Zero Standard V2.0 recognises a contribution budget, an amount per tonne of your remaining emissions, as one way to take responsibility for ongoing emissions. A euro-based claim fits that approach:
“In 2026 we contributed €60,000 to verified climate projects, equal to €40 per tonne of our remaining scope 1 and 2 emissions. The projects and the registry records are listed here: [link].”
A euro figure reads as responsibility, which makes it one of the safer formats. It still needs the same evidence behind it.
Tip from Bernard de Wit, Co-founder of Regreener: “Most of the claims we help rewrite come out stronger. ‘Carbon neutral’ told a customer nothing they could check. ‘We financed 2,000 tonnes from this project, here is the registry record’ tells them exactly what you did. Specific beats impressive.”
The evidence each claim needs
Every contribution claim rests on the same evidence:
Retirement records from the registry, with serial numbers retired in your company’s name.
Project details: name, type, country and standard.
Volume or amount and the period it covers, matching what you report elsewhere, including any CSRD sustainability statement.
A public page where readers can check the project and the retirement.
Separation from your own emissions data, so credits are never presented as a reduction.
Credit quality matters as much as the wording. A precisely worded claim about a project with weak additionality or unresolved leakage is still a claim a journalist will test. That is why every project Regreener offers goes through our 100+ datapoint quality framework before we put it in a client’s portfolio.
In the Netherlands
The Netherlands implemented EmpCo in Book 6 of the Civil Code, and the ACM enforces it. The ACM’s own guidance page is direct: sustainability claims about a product or service may not be based on compensating greenhouse gas emissions. Contribution claims remain possible under the same transparency conditions as elsewhere in the EU. For practical tips beyond carbon credits, see our do’s and don’ts for green marketing.
Test your own wording
The fastest way to get this right is to take every claim you currently use, on the website, in proposals, on packaging and in signatures, and test each one. Regreener’s free EmpCo Claim Checker does that for claims about carbon credits: answer three questions per claim and get the outcome, the legal source and a contribution claim you can use instead.
If the wording is settled but the credits behind it need a second look, talk to a Climate Strategist.
