Can I say "carbon neutral" in the UK?

Why "carbon neutral" is treated as high-risk

The problem is the gap between what a shopper hears and what is true. Consumer research the ASA relied on found that people tend to read "carbon neutral" as meaning a product's emissions have been reduced to nothing — and feel misled when they learn it actually relies on buying offsets elsewhere. That reaction is exactly what the rules are built to prevent.

Against the CMA Green Claims Code, an offset-based neutrality claim can fail three principles at once:

• Principle 1 (truthful and accurate) — it implies a reduction at product level that has not happened.
• Principle 3 (not omitting important information) — it hides that the "neutral" figure rests on offsetting.
• Principle 6 (substantiated) — the offsetting itself, and the underlying figures, are hard to evidence to the standard the Code expects.

What the ASA has actually done

In advertising, the ASA enforces the CAP/BCAP Code separately from the CMA, and it has acted on carbon-neutral claims. It has upheld complaints against carbon-neutral and carbon-negative advertising where the ad did not make clear the claim depended on offsetting — including rulings involving well-known brands. Its published guidance advises marketers to avoid unqualified "carbon neutral" and "net zero" claims, and, where offsetting is involved, to say so and explain the basis. We describe only rulings and guidance the ASA has itself published; we don't invent case outcomes.

When you can make a neutrality claim

A carbon-neutral claim is not automatically off-limits — but the wording and the evidence have to carry it:

• Lead with the real reduction. Put the genuine, evidenced cut you have actually made up front ("28% lower emissions per unit versus 2021, independently verified"). That is a claim about something you did.
• Disclose offsetting plainly and near the claim. If offsets are part of the picture, say so in plain words close to the claim, name the scheme, and explain its basis — don't bury it in a footnote or a separate page.
• Don't present the offset "net" figure as the headline. The net-of-offsets number is the part most likely to mislead; it should not be the loudest thing on the pack or the ad.
• Hold the evidence. Keep the underlying calculation, the offset scheme detail and any verification where a consumer could reach it.

UK vs EU: an important difference

If you also sell to EU consumers, note the regimes diverge. The EU's Empowering Consumers Directive introduces specific restrictions on offset-based carbon-neutral claims from September 2026. UK law has no equivalent statutory ban — the claim is caught through the general misleading-practices provisions and the Code instead. That means in the UK the test is "does this mislead?" rather than "is this on a banned list." Our EU edition covers the EU rules; this page is UK law.

Frequently asked questions

Sources

• CMA Green Claims Code (2021) — principles 1, 3 and 6, which offset-based neutrality claims most engage. gov.uk — Green Claims Code
• ASA/CAP guidance: carbon offsetting and carbon neutral — the advertising rules on carbon-neutral and net-zero claims (CAP Code rule 11.1). asa.org.uk — Environmental claims: carbon offsetting and carbon neutral
• Digital Markets, Competition and Consumers Act 2024 — the unfair-trading provisions (Part 4) that catch misleading environmental claims; in force 6 April 2025. legislation.gov.uk/ukpga/2024/13

Content current as of 9 July 2026. ASA guidance and the CMA/DMCCA position can change — re-check the primary source before acting on anything time-sensitive.