Trump (with risks) in marketing: climate-neutral products

© iStock | Parradee Kietsirikul

Marketing has (rightly) recognised the topic of climate-neutral products as a purchase criterion and is increasingly advertising CO2 neutrality. But how do you go about it in a serious and scientific way? Because a greenwashing accusation quickly turns the supposed sales argument into its opposite. We shed light on how national and European regulators have addressed the issue and what ways there are to act as safely as possible at company and product levels.


A wide variety of products now advertise their “climate neutrality” – from Katjes to the Balea body care products from dm. Vilsa-Brunnen even goes one step further and promises that its own products are climate positive. This means that a product gives more back to nature than it has taken from it.

For consumers, such aspects are certainly important for their purchase decision. At the same time, companies should be wary of taking the use of climate attributes lightly. Because even the suspicion of greenwashing can easily lead to a shitstorm, especially on social media. The EU has already taken up the issue.


The consumers want it

In January 2021, the Hamburg-based opinion research institute Appinio conducted a representative survey of 1,000 people between the ages of 16 and 65 on the topic of climate protection.

Relevant core results:

  • More than 90 percent of consumers consider climate protection important in general.
  • 50 percent already pay attention to information on the CO2 emissions of products, especially for food and drugstore items.
  • For 74 percent of respondents, the climate aspect is a decision-making aid when shopping.

The question is how to prove the climate benefits of your product and its packaging credibly and as incontestably as possible. Here it is important to distinguish between the corporate and the product level.


The corporate level

At the corporate level, the question has become easier to answer, as more and more companies have committed to science-based climate targets in line with the Science Based Targets initiative (SBTi). The procedure for creating a corporate carbon footprint and a climate strategy is also described relatively clearly in terms of methodology, even if it is subject to dynamic further development. According to the “scientific model”, offsets are only allowed as soon as around 90 percent of the emissions generated have been reduced by other means according to the Greenhouse Gas Protocol (GHG).


The product level

On the product level, the situation is less clear.

On the one hand, there is the international specification PAS 2060, which is considered the first valid set of rules for climate neutrality. It was first published by the British Standards Institution (BSI) in 2010.

According to PAS 2060, a central criterion for achieving climate neutrality is the reduction of the carbon footprint. To achieve this, the company must develop and successfully implement a Carbon Footprint Management Plan.

Only then may the remaining emissions be offset with emission reduction certificates (climate protection certificates) or made climate neutral. These certificates must also fulfil specific criteria according to PAS 2060.


On the other hand, unlike SBTi, an exception is allowed in the first year of climate neutrality under PAS 2060. Specifically, climate neutrality may be achieved for the first performance period through 100 percent offsetting via certificates. This regulation and the type of compensation allowed have already increasingly led to greenwashing accusations. REWE, for example, earned the “Goldener Windbeutel” from Foodwatch in this way (link).


The international standard ISO 14068 “Greenhouse gas management and associated activities – Carbon neutrality” could offer a way out. However, it is still at the drafting stage. In future, it is to provide clear definitions and parameters for CO₂ neutrality, for which some of the content will be taken from the PAS 2060 specification.


Federal Environment Agency warns against greenwashing

The UBA points out that the term “climate neutral” is not protected by law. It merely indicates that the company makes compensatory payments for the emissions that occur during the production of the product.

It is therefore no coincidence that the “best-selling climate-neutral” product is increasingly the subject of warning letters. So far, three rulings and several ongoing proceedings indicate a clear direction: According to the courts, the term “climate neutral” may not be used as a blanket term because it is not transparent.


The crux

The criticism is not aimed at CO2 compensation per se; quite the opposite. Since the Kyoto Protocol in 2005, it is even expressly desired to combat climate change – but in the right order: first avoid, then reduce and only then compensate.


Companies take the initiative

Many companies are aware of the problems and are reacting to them. For example, FRoSTA, mymuesli, Nestlé Germany and Oatly, together with the climate protection organisation GermanZero and with the support of the Global Impact Alliance and the Collaborative Marketplace COBIOM, have founded an “initiative for more CO₂e transparency in the food industry”. Its name: Together for Carbon Labelling (TCL). Within the framework of TCL, an industry-wide standard is to be developed – initially in and for Germany – for the transparent collection and communication of a product’s CO₂e emissions.


On the agenda of the EU regulators

The EU regulators are currently working on a Green Claim Regulation. A first draft has already been published for comment. It does not yet allow a final opinion, but already indicates that the general claim “climate neutral” will no longer be permissible without a supplementary explanation of the underlying specification or certification.

It is also possible that the issue will be decided by the methodologically mandatory EU requirement of a specific Product Environmental Footprint (PEF). The PEF is a method for measuring sustainability performance that was developed by the EU Commission in cooperation with companies and experts. It aims to improve the informative value and comparability of environmental performance assessment compared to existing methods. To this end, all relevant environmental and health impacts as well as resource-related burdens caused by a product are identified.



An increasing number of consumers want to make a contribution to climate protection when shopping. This is only to be welcomed and imperative for combating the climate crisis and achieving the climate goals. Many brand owners have recognised this and are looking for ways to meet this demand. However, this can only be done in a reliable, recognised and communication-safe manner with the help of politics. It must provide the necessary, binding legal framework – as soon as possible.

You can also find more on this topic in the politics section of this newsletter. There we take a closer look at the EU’s planned new “Green Claims” regulation.

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