Carbon Market Watch’s Submission to the Federal Trade Commission’s (FTC) request for public comment on potential revision of its “Green Guides”

Carbon Market Watch argues that the FTC's 'Green Guides' are outdated and fail to align with the Paris Agreement's 1.5C goal. The submission recommends a total ban on claims such as 'carbon neutral' and 'net zero' because they falsely imply that emissions can be 'neutralised' through carbon credits, which the author describes as scientifically unsound. Instead, the document proposes a 'contribution' model where companies fund mitigation projects without claiming to offset their own emissions. It also suggests that the Guides be made enforceable under the FTC Act to provide oversight of the voluntary carbon market and protect consumers from greenwashing.

• The current FTC Green Guides are outdated as the last revision occurred over a decade ago, predating the Paris Agreement and the 1.5C global heating limit.
• Carbon Market Watch recommends a 'blacklist' of prohibited claims that are considered inherently deceptive because they imply emissions are 'neutralised' or 'cancelled out' via carbon credits. This list includes terms such as 'carbon neutral', 'climate neutral', 'climate positive', 'climate negative', 'CO2 compensated', and 'net zero'.
• The document argues that 'tonne-for-tonne' offsetting is an 'illusion' because carbon credits on the voluntary carbon market (VCM) lack integrity, specifically regarding permanence, additionality, and accurate baseline estimations.
• The submission proposes replacing the offsetting model with a 'contribution' model, where companies truthfully report financial investments in mitigation projects without claiming to compensate for their own climate impact.
• Consumer research indicates widespread misunderstanding of climate claims; for example, a 2022 Morning Consult survey found that most US consumers do not know what 'carbon neutral' means.
• Carbon Market Watch advocates for the Green Guides to be incorporated into a compulsory rule under the FTC Act to ensure enforceability and provide oversight for the unregulated voluntary carbon market.

APA

Carbon Market Watch (n.d.). Carbon Market Watch’s Submission to the Federal Trade Commission’s (FTC) request for public comment on potential revision of its “Green Guides”. https://carbonmarketwatch.org/wp-content/uploads/2023/06/FTC-Consultation-_Carbon-Market-Watch.pdf

Chicago

Carbon Market Watch. Carbon Market Watch’s Submission to the Federal Trade Commission’s (FTC) request for public comment on potential revision of its “Green Guides”. n.d. https://carbonmarketwatch.org/wp-content/uploads/2023/06/FTC-Consultation-_Carbon-Market-Watch.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch’s Submission to the Federal Trade Commission’s (FTC) request for public comment on potential revision of its “Green Guides” |url=https://carbonmarketwatch.org/wp-content/uploads/2023/06/FTC-Consultation-_Carbon-Market-Watch.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatchndcarbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch’s Submission to the Federal Trade Commission’s (FTC) request for public comment on potential revision of its “Green Guides”}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2023/06/FTC-Consultation-_Carbon-Market-Watch.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }