Environmental claims printed on packaging are about to come under tighter scrutiny in the European Union. From September 27, 2026, businesses marketing products and services to EU consumers face new restrictions on claims such as “carbon neutral,” “climate neutral” and “carbon positive,” particularly when those claims depend on carbon offsets outside the product’s value chain.
For packaging suppliers, brand owners and other companies selling packaged goods into Europe, the practical issue is straightforward: claims already appearing on packs, labels and related marketing materials may need to be reviewed.
The change stems from the EU’s Directive on Empowering Consumers for the Green Transition, Directive (EU) 2024/825. Member states were required to incorporate the directive into national law by March 27, 2026, with the new provisions taking effect September 27.
Ellis Clark, Head of Marketing at Tunley Environmental, argues that the change should not be described simply as a blanket ban on the words “carbon neutral.” The bigger issue is how the claim is supported. “This does not amount to a universal ban on the words ‘carbon neutral’,” Clark writes in a recent article. “However, it represents a significant change in how EU carbon neutral claims can be made and substantiated.”
Offset-Based Claims Face the Biggest Change
The most immediate concern involves product claims based on purchased carbon credits or other offsetting activity outside the product’s value chain. Under the new rules, a business generally cannot calculate the emissions associated with a product, buy enough outside carbon credits to offset those emissions, and then market the product to consumers as carbon neutral on that basis.
Tunley identifies examples that could be affected, including:
- Carbon-neutral delivery
- Climate-neutral product or service
- Carbon-positive product
- Climate compensated
- Net zero product
The restriction applies where the claim depends on offsetting greenhouse gas emissions outside the product’s own value chain. Independent certification or the quality of the carbon credits does not, by itself, make that type of consumer claim acceptable under the directive. Companies can still invest in carbon reduction or removal projects. What changes is how that activity can be translated into a claim about the product itself.
Specific Claims May Be Safer Than Broad Green Language
The directive also raises the bar for generic environmental claims. Terms such as “carbon neutral,” “climate neutral,” “carbon compensated” and “carbon positive” may be treated as generic environmental claims unless the company can demonstrate recognized excellent environmental performance relevant to the claim.
Instead of putting a broad claim such as “low-carbon packaging” on a pack, a company may be better served by describing a documented reduction against a defined baseline, provided the comparison is accurate and properly substantiated.
Tunley gives the example of a statement such as: “This product has 30% lower cradle-to-gate greenhouse gas emissions than its 2023 equivalent.” That type of statement is more specific than simply calling a product low carbon, although it still requires credible methodology, current evidence and a clearly defined scope.
For packaging companies already investing in lightweighting, recycled content, material substitution, reusable packaging systems or manufacturing efficiency, that may be an important distinction. The message increasingly needs to describe what actually changed rather than relying on a broad environmental label.
LCA Still Has a Role
Life Cycle Assessment remains important. The new rules do not prohibit companies from making claims based on real reductions within a product’s value chain. A robust LCA can help document emissions associated with raw materials, manufacturing, distribution, use and end-of-life. That could support claims involving reduced emissions compared with an earlier product design or another clearly defined baseline.
But completing an LCA does not provide a free pass to use any environmental wording a marketer chooses. The claim still needs to accurately reflect what the assessment demonstrates.
The same applies to ISO 14068-1. Tunley notes that the standard remains useful for structuring carbon-neutrality programs and prioritizing emissions reductions before the use of carbon credits, but following the standard does not override EU consumer law. In practical terms, there are two separate questions: has the company followed a credible process to measure and reduce emissions, and is the resulting consumer-facing claim legally permissible?
The new rules also extend beyond current product claims. Businesses making forward-looking statements such as “carbon neutral by 2030” or “net zero by 2040” will need more than an aspirational target. According to the Tunley article, future environmental claims must be backed by a detailed and realistic implementation plan, measurable and time-bound targets, appropriate resources and regular third-party verification.
Do Not Forget Packaging Already in the Supply Chain
One of the most practical points in Tunley’s guidance concerns existing inventory. The European Commission’s guidance indicates that the rules can affect products already in the distribution chain. Companies may therefore need to review packaging already printed with claims that will no longer comply and determine whether those statements need to be covered, corrected or otherwise addressed.
Companies with large inventories of printed cartons, labels, flexible packaging or other branded materials may want to determine how much affected packaging remains in stock, how quickly it will be consumed and whether replacement artwork should be accelerated.
What Packaging Companies Should Review
A useful first step is to inventory environmental claims across all consumer touchpoints. That includes packaging, labels, websites, retailer listings, advertising, brochures, product names and social media.
Then look at the substance behind each claim:
- Is it a product-level or company-level statement?
- Does it describe a current achievement or a future goal?
- Does it rely on carbon offsets?
- What emissions boundary is being measured?
- Is there an LCA or other supporting methodology?
- Is the evidence current?
- Could the claim be expressed more specifically?
- Is the same wording already printed on packaging in inventory?
As Clark notes, the objective is not necessarily to stop communicating environmental performance. It is to make the claim narrower, clearer, and more defensible.
Rick LeBlanc, EMBA, is the founder and editor of Reusable Packaging News (subscribe to the free newsletter) and editor of Western Pallet Magazine. A supply chain journalist with more than 30 years of experience, he specializes in pallets, reusable packaging, material handling and related operations. Rick is co-author of Pallets: A North American Perspective and Pallets & Progress: A Collected History of Pallets and Palletized Handling 1922–1945. He is also an advisory board member of the Virginia Tech Center for Packaging and Unit Load Design. Read Rick’s full bio.
