Your Carbon Claims Are About to Need Receipts

From September 27, 2026, companies marketing products to consumers in the EU will face stricter rules for environmental claims. The EU’s Empowering Consumers for the Green Transition Directive, or ECGT, prohibits claims that a product has a neutral, reduced, or positive greenhouse-gas impact when that claim rests on offsetting emissions outside the product’s own value chain. It also restricts generic claims such as “carbon neutral,” “climate neutral,” “green,” and “eco-friendly” unless the trader can demonstrate the level of environmental performance required for the claim.

The practical consequence is not that companies must stop measuring product footprints or communicating genuine environmental improvements. It is that the language used on packaging, product pages, sales materials, and advertising must be supported by evidence that can withstand scrutiny. A company needs to know exactly which product configuration the claim describes, which emissions inputs were used, where those inputs came from, what lifecycle boundary was applied, and whether the evidence still applies after the product changes.

For formulation-led businesses, that makes carbon-claim compliance a product-data problem before it becomes a marketing problem. A footprint number cannot be treated as a static property of a product name when the underlying formula, supplier base, manufacturing conditions, packaging configuration, or market version may continue to evolve.

‍

The ECGT raises the bar for product claims

The ECGT, formally Directive (EU) 2024/825, updates EU consumer-protection law to address misleading environmental claims, unreliable sustainability labels, and other practices that can prevent consumers from making informed purchasing decisions. It applies from September 27, 2026, and affects business-to-consumer commercial practices, including voluntary environmental claims made in product marketing.

The directive does not say that every carbon-related statement is prohibited. Nor does it prevent companies from communicating actual emissions-reduction work or discussing investments in environmental projects. Its central distinction is between the environmental performance of the product itself and claims that rely on external offsetting to create an impression of neutrality or net-positive impact.

Under the new rules, a business cannot state or imply that a product has a neutral, reduced, or positive greenhouse-gas impact because it has purchased carbon credits for emissions reductions outside that product’s value chain. The European Commission’s FAQ also explains that generic claims such as “carbon neutral,” “carbon compensated,” “climate neutral,” and “carbon positive” are prohibited unless the trader can demonstrate recognized excellent environmental performance that is relevant to the claim.

That matters because many organizations have historically treated offsetting, corporate targets, product-footprint calculations, and consumer-facing claims as related but separate activities. The ECGT makes the connection much harder to ignore. If a company makes a claim about a particular product, it needs evidence about that particular product.

‍

The claim must stay connected to the product

A carbon-footprint figure is not meaningful in isolation. It only becomes useful when the organization can explain what it describes.

Take a product described as having a “lower carbon footprint.” The obvious question is lower than what: an earlier formulation, a previous product generation, an internal baseline, a market average, or a competitor product? The next question is whether the two products were assessed on comparable terms. Were the same lifecycle stages included? Were the same emissions-factor sources, geographic assumptions, allocation rules, and data-quality thresholds applied? Is the comparison still current after either product changed?

The ECGT is especially relevant here because comparative environmental claims must be based on material and verifiable product features. They must compare products that serve the same function using a common method and common assumptions, and consumers must be given information about the comparison method, the products and suppliers involved, and the measures used to keep the information current.

For an R&D-driven company, the evidence must therefore attach to a defined product configuration. Depending on the business, that may mean an approved formula version, a bill of materials, an ingredient set, an SKU, a package format, a manufacturing scenario, or a particular market variant. The right unit will vary, but the principle does not: the calculation and claim need to describe a product that can be identified, retrieved, and compared.

This is where many footprint projects become fragile. The organization may calculate a footprint for an earlier formula, then approve a substitute ingredient, shift to a new supplier, change material concentrations, adjust the manufacturing route, or introduce a different packaging component. The product may still meet quality and performance requirements, but the public carbon claim may no longer rest on the same product evidence.

‍

Carbon evidence needs three things

A defensible claim starts with traceable inputs. The organization should be able to identify the important emissions factors used in the calculation and explain whether each is supplier-specific primary data, a recognized lifecycle-assessment database value, an internal estimate, or another documented assumption. It should retain information about the source, applicable geography, date, version, methodology, and relevance of the factor, particularly when the factor has a material effect on the product result.

In formulation-intensive industries, this often begins with ingredients and materials. The calculation may depend on the emissions factors associated with resins, solvents, pigments, additives, polymers, minerals, packaging components, botanical extracts, biological feedstocks, or other inputs. Those factors should remain connected to the material and to the formulation version that uses them. Otherwise, the carbon calculation becomes an isolated spreadsheet whose relationship to the live product record must be manually reconstructed every time a question arises.

The second requirement is a clear and consistent boundary. A cradle-to-gate number describes a different scope from a cradle-to-grave number, while a gate-to-gate calculation serves another purpose again. No single boundary is inherently correct in every situation; the appropriate method depends on the product, intended use, claim, market, available data, and assessment framework. What matters is that the organization can explain the scope clearly and apply it consistently when it makes a comparison.

The third requirement is an approval and change history. The organization should be able to show when the calculation was prepared, which product version it covered, who reviewed it, what claim wording was approved, and which subsequent changes would require reassessment. This is the “receipt” behind the claim: not merely a final footprint number, but the record showing how that number relates to a defined product and a controlled set of assumptions.

‍

Why this is an R&D issue

Marketing teams determine how a claim appears in the market. Sustainability teams may establish lifecycle-assessment methodology, maintain emissions factors, or manage corporate emissions reporting. Regulatory and legal teams may decide whether a proposed phrase can be used in a particular country or channel.

None of those functions, however, creates the product evidence on its own.

That evidence begins with product-development decisions: selecting a raw material, changing a supplier, revising a formula, qualifying a substitute ingredient, moving a process to a new site, changing a package format, or releasing a new SKU configuration. Each decision can affect the inputs or assumptions behind a footprint calculation. Each may require an existing claim to be reviewed before it continues to appear on a label or product page.

The right response is not to make R&D responsible for legal interpretation or consumer communication. It is to make product changes visible to the people responsible for environmental claims. R&D and product teams need to maintain the formula, material, supplier, and version context. Procurement teams need to maintain sourcing information. Sustainability teams need to govern emissions factors and methodology. Quality teams need to control changes and retain approval evidence. Marketing, legal, and regulatory teams need to use that evidence to approve language that is accurate for the product and market.

When those records exist in disconnected systems, the claim-review process is slow, manual, and vulnerable to error. When they are connected, a product change can trigger the right question: does this change affect the evidence behind the claim?

‍

The most common risk is stale substantiation

The greatest operational risk is not only publishing an inaccurate footprint calculation on day one. It is allowing a calculation that was once appropriate to become detached from the product as the product changes.

Imagine a company has made a footprint claim using supplier-specific information for a major ingredient. A supply disruption then leads procurement and R&D to approve a substitute source. The substitute passes incoming quality controls and performs adequately in the finished product, but it has a different origin, processing route, or emissions factor. The formulation is still viable and the product still meets specification. Yet the claim may need reassessment because the evidence behind it has changed.

The same is true when a team reduces costs by changing a binder ratio, replaces a pigment, modifies active content, reformulates around a new regulatory requirement, changes packaging weight, or moves production between sites. These can be legitimate, controlled decisions. They become a carbon-claim issue only when the organization has no reliable way to identify whether the change affected the product configuration or calculation assumptions behind the claim.

That is why carbon evidence should be managed as part of the product lifecycle rather than collected only when a sustainability report or marketing campaign is due.

‍

Test one live claim

A practical place to begin is with a carbon or environmental claim that is already live, planned, or under review for an EU consumer market. Rather than starting with a full portfolio audit, select one representative claim and ask a cross-functional group to retrieve the evidence behind it.

The team should be able to identify the exact formula, product version, SKU, or configuration to which the claim applies; the relevant material and supplier assumptions; the source and version of the significant emissions factors; the lifecycle boundary and methodology; the date of the calculation; the market and claim wording; and the approval record. They should also be able to identify the types of product change that would require the calculation or claim to be reconsidered.

If that requires a long search through email, spreadsheets, supplier PDFs, folders, and the memory of a few specialists, the organization has identified the gap. The issue is not necessarily that the footprint calculation is wrong. It is that the company cannot readily show how the claim relates to the current product.

‍

Build the evidence before the claim

Organizations do not need to wait for a challenge from a regulator, customer, competitor, or consumer group before putting this evidence in order. They can begin by connecting formulation versions, material and supplier information, emissions factors, calculation assumptions, product configurations, change decisions, and approved claim language in a controlled record.

That is not a substitute for lifecycle-assessment expertise, third-party verification where appropriate, legal review, or a claim-specific interpretation of applicable law. The exact evidence required will depend on the product, market, methodology, and wording of the claim.

It is, however, the operating foundation that allows those specialists to work with current, traceable information. A connected R&D and product-data record gives teams a way to understand what a claim applies to, what evidence supports it, and when a formulation or supply-chain change requires review.

For construction-materials and coatings companies, the same foundation can support emerging Digital Product Passport requirements, although the two topics are not the same. Digital Product Passports focus on how product information, including composition, origin, embodied carbon, and circularity information, can be structured and shared across the value chain. Read The Digital Product Passport for Construction Products and Coatings for that DPP-specific challenge.

For a sector-specific look at how formulation choices can reduce embodied carbon before claims are made, read The Data Behind Lower-Carbon Cement.

Request a demo to see how Uncountable connects formulation, material, supplier, quality, and product data so teams can maintain traceable evidence as products and environmental claims evolve.