Carbon Market Watch’s Submission to India’s Central Consumer Protection Authority request for public comment on its draft guidelines to combat greenwashing

Carbon Market Watch argues that the Central Consumer Protection Authority should explicitly ban "carbon neutral" and offsetting claims rather than merely requiring their substantiation. The organization contends that offsetting is fundamentally flawed due to quantification uncertainties, lack of permanence in biological sinks, and consumer misunderstanding. Instead, it proposes a "contribution" or "beyond value chain mitigation" (BVCM) model. The submission also recommends stricter requirements for future climate targets, including science-based commitments, full scope 1, 2, and 3 emissions disclosure, and alignment of corporate lobbying with the Paris Agreement.

• Carbon Market Watch argues that the draft guidelines should explicitly ban all offsetting and neutrality claims, such as "carbon neutral" or "climate positive", because substantiating them is insufficient to prevent the marketing of "dirty" products as "green".
• The document identifies three primary technical flaws in offsetting: quantification uncertainty where it is "difficult to accurately quantify the climate benefits associated with a credit"; low credit quality regarding permanence, as biological sinks are vulnerable to natural disasters; and inaccurate baseline estimations that lead to over-issuance of credits.
• Offsetting claims are described as "mitigation deterrents" because consumers often misunderstand the terminology, leading them to believe their current behavior is sufficient and reducing the motivation to shift toward truly sustainable products.
• The submission recommends replacing the compensation model with a "contribution" or "beyond value chain mitigation" (BVCM) model, where companies provide climate finance without claiming to have "neutralised" emissions.
• For future climate targets to be credible, the document asserts they must be based on science-based, verifiable commitments and include a concrete implementation plan with time-bound targets for internal operations and value chains.
• The organization emphasizes that corporate climate claims are undermined if a company's lobbying activities are not aligned with the Paris Agreement, citing that 58% of almost 300 Forbes 2,000 companies are at risk of "net zero greenwash" due to their policy engagement.
• To ensure transparency, the document recommends that companies disclose all direct and indirect emissions across the entire value chain (scopes 1, 2, and 3) and set short-term (3-5 years), medium-term (5-10 years), and long-term targets (90-95% reduction by 2050 or sooner).

APA

Carbon Market Watch (n.d.). Carbon Market Watch’s Submission to India’s Central Consumer Protection Authority request for public comment on its draft guidelines to combat greenwashing. https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW-Indian-consultation-on-Green-Claims.pdf

Chicago

Carbon Market Watch. Carbon Market Watch’s Submission to India’s Central Consumer Protection Authority request for public comment on its draft guidelines to combat greenwashing. n.d. https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW-Indian-consultation-on-Green-Claims.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch’s Submission to India’s Central Consumer Protection Authority request for public comment on its draft guidelines to combat greenwashing |url=https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW-Indian-consultation-on-Green-Claims.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatchndcarbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch’s Submission to India’s Central Consumer Protection Authority request for public comment on its draft guidelines to combat greenwashing}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2024/04/04-2024-CMW-Indian-consultation-on-Green-Claims.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }