Is “climate neutral” prohibited from 2026?

It is not the word that is prohibited but the basis behind it. What is prohibited is a product-related claim that rests on the offsetting of greenhouse gas emissions and states that the product has a neutral, reduced or positive impact on the environment. The same applies to “CO2 neutral”, “CO2 positive” and “climate friendly” where offsetting payments are the basis.

The rule sits as number 4c on the blacklist in the annex to section 3(3) of the German Unfair Competition Act and has applied since 27 September 2026 without any case-by-case assessment. It therefore does not matter whether the claim actually misleads in the individual case, nor whether the offsetting projects are sound.

What remains permissible

The claim remains permissible where the product genuinely is climate neutral across its entire life cycle, that is without offsetting. That is the difference between a property and an accounting exercise.

Statements that name and substantiate an actual reduction also remain permissible, for example a quantified cut in emissions against a clearly described baseline. Anyone stating future targets needs clear, objective, publicly available and verifiable commitments; a declaration of intent is not enough.

What this means for packaging

Climate claims on packaging are often the most convenient way to assert sustainability, and from the application date they are the riskiest. The way out is not a different wording of the same claim but a measurable product property: a declared recycled content, verified recyclability, tested freedom from microplastics or a substantiated plastic content below a threshold. Such statements are verifiable, they rest on a published programme, and they fall under none of the six numbers.

And stock with a printed climate claim?

There is no general sell-off period. For goods already on the market the Commission services name covering or correcting the claim and adding supplementary information at the point of sale. Online the claim should go first: there it can be changed without lead time.