RULES AND GUIDANCE ON GREEN CLAIMS

Legislators, consumer authorities and advertising or industry bodies can establish rules explaining which environmental claims organisations may make and what evidence and qualifications those claims require. The lever includes binding restrictions in law, guidance explaining existing legal duties and voluntary codes used by participating businesses. For carbon removal, these rules can distinguish a factual statement about financing a project from a claim about a product's footprint or a company's net-zero performance. Clear, usable requirements help businesses communicate credible purchases and help consumers understand what those purchases achieve. They can also prohibit claims that remain misleading even when the underlying credit is certified. The intervention governs the evidence and presentation of communications; CDR disclosure supplies the underlying information, while a claims taxonomy defines particular named categories and their eligibility requirements.

The responsible body should explain whether each provision is law, an interpretation of existing law or voluntary practice, and identify who can enforce it. Requirements should address the overall impression of a claim, including its wording, imagery, time period and the activities it covers. Evidence must distinguish actual product performance from compensation through credits purchased elsewhere. The rules should give businesses practical ways to explain legitimate removal commitments and completed purchases, with stronger evidence for more expansive claims. Legislators must also decide whether claims need checking before publication or can be investigated afterwards. That choice affects compliance costs, access to reviewers and the authority's workload. Guidance and voluntary schemes must respect existing legal restrictions, including in markets reached by cross-border advertising.

Shared rules can reduce the time businesses spend determining how to communicate climate action and make credible CDR purchases easier to explain to customers. Practical examples can support first-time buyers as well as experienced advertisers, while enforcement reduces the advantage gained by unsupported claims. Legislation can extend consistent requirements beyond firms that volunteer to follow a code. Voluntary guidance can be tested and updated more quickly, helping establish workable practice before formal regulation. The opportunity is to combine a useful route for truthful communication with meaningful protection against misleading claims; some restrictions will redirect demand away from particular offset uses rather than increase total removal spending.

Lenient rules can legitimise misleading claims, while disproportionate evidence or checking requirements can deter truthful communication and discourage smaller companies from participating. Divergent national rules can fragment marketing practice, and voluntary guidance has limited effect when businesses can disregard it without consequences. Legislative negotiation can also stall when verification duties and burdens are poorly resolved. The EU's proposed Green Claims Directive remains blocked after negotiations stopped in June 2025, even though the separate Empowering Consumers for the Green Transition Directive was adopted. The experience supports early testing of costs and enforcement capacity, while warning against treating a proposed regime as settled law. Greater legal clarity may change the value of existing credit-based marketing strategies.

Authorities and scheme owners should assess whether audiences understand claims and whether businesses can communicate credible action without disproportionate effort. Repeated samples of advertising, consumer comprehension tests, evidence reviews and corrected claims can reveal recurring problems. Business surveys can identify withdrawals of useful information or barriers faced by smaller advertisers. Complaint volumes should be considered alongside awareness and enforcement activity, since better access to complaints may initially increase reported cases. The findings should inform revisions to examples, checking requirements and enforcement priorities, with attention to both misleading claims and avoidable uncertainty about lawful communication.

Consumer authorities and advertising bodies should work with legal experts, consumer organisations and CDR specialists to determine which evidence supports each type of claim. Large and small businesses should test the preparation effort and explain how wording affects purchasing and communication decisions. Independent reviewers can identify verification limits, while regulators in different markets should align interpretations where their laws permit. Public complaint routes should allow audiences to challenge misleading claims.

Supranational, national and state legislators or consumer authorities can set binding requirements where they hold relevant powers. Existing authorities can explain and enforce those requirements. International bodies and industry associations can issue common principles and voluntary advertising codes, with effect through business adoption or scheme rules. Their guidance does not override applicable law. Municipalities are not generally included as independent claims regulators, and philanthropic support for a code does not by itself make a foundation the actor setting or enforcing it.