Green Claims Directive: Open Consultation
Summary
Carbon Market Watch criticizes the proposed Green Claims Directive (GCD) for allowing the continued use of carbon neutrality and offsetting claims, which the organization asserts are inherently misleading due to quantification uncertainties, low carbon credit quality, and consumer misunderstanding. The response argues that the GCD's substantiation rules are too weak to prevent greenwashing and that the directive lacks clear definitions for 'significant' environmental impacts and specific requirements for future performance claims.
Key insights
- The Green Claims Directive (GCD) fails to meet its objectives of curbing greenwashing and protecting consumers because it does not ban neutrality claims, such as "carbon neutral", "climate neutral", "climate positive", "climate negative", and "CO2 compensated".
- Carbon offsetting and neutrality claims are problematic due to scientific uncertainty regarding "tonne-for-tonne" offsetting, the lack of permanence in biological carbon sinks (such as forestry projects susceptible to wildfires), and a lack of additionality in many projects, including large-scale renewable energy.
- The GCD's proposed substantiation rules, specifically Article 3.1(h), are considered insufficient because they only require companies to provide carbon offset information as "additional environmental information" rather than requiring separation within the actual claims or advertisements.
- The directive contains vague language regarding future environmental performance claims (e.g., "net zero by 2050") and fails to define the term "significant" in Article 3.1(d), which could allow companies to ignore indirect emissions (scope 3) while claiming carbon neutrality.
Cite the original document
- APA
- Carbon Market Watch (n.d.). Green Claims Directive: Open Consultation. https://carbonmarketwatch.org/wp-content/uploads/2023/07/Green-Claims-Consultation.pdf
- Chicago
- Carbon Market Watch. Green Claims Directive: Open Consultation. n.d. https://carbonmarketwatch.org/wp-content/uploads/2023/07/Green-Claims-Consultation.pdf.
- Wikipedia
- {{cite press release |author=Carbon Market Watch |title=Green Claims Directive: Open Consultation |url=https://carbonmarketwatch.org/wp-content/uploads/2023/07/Green-Claims-Consultation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @misc{carbonmarketwatchndgreen, author = {{Carbon Market Watch}}, title = {{Green Claims Directive: Open Consultation}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2023/07/Green-Claims-Consultation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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