Carbon neutral, climate positive, and the offsetting problem

01Why this claim is under pressure

Environmental claims in UK consumer markets are receiving more regulatory attention than any other claim category. The Competition and Markets Authority has published guidance for businesses on making environmental claims, setting out principles including that claims must be truthful and accurate, must be clear and unambiguous, must not omit or hide important information, and must consider the full life cycle where relevant.

The Advertising Standards Authority applies the advertising codes to green claims and has ruled against advertisers for unsubstantiated or misleading environmental messaging. This is the mechanism most likely to reshape how grooming products talk about sustainability, and it works on specifics rather than on vibes.

02What carbon neutral actually asserts

A carbon neutral claim normally asserts that emissions associated with a defined boundary have been calculated and that an equivalent quantity has been compensated through purchased offsets. Three variables determine whether that assertion means anything, and none of them appears on a bottle.

The boundary determines what was counted. The methodology determines how. The offset type determines what was bought. A claim covering only a factory's energy use, calculated on a permissive methodology, compensated with low quality credits, produces the same two words on a pack as a rigorous full life cycle assessment with high integrity removals.

03The boundary problem, in grooming specifically

For a cosmetic product, emissions are distributed across agricultural or petrochemical raw material production, ingredient processing, packaging manufacture, filling, distribution, retail, consumer use and end of life. For rinse off products, consumer use is frequently a large share, because heating water is energy intensive.

That last point is the one most often left out and the one most relevant to shower products. A shampoo's footprint is heavily influenced by how long the user stands under hot water, which is outside the manufacturer's boundary and inside the product's actual impact. This is why we treat use phase as a category in the index rather than as an afterthought.

04Offsets, and why they are contested

Offsetting rests on the idea that a tonne of emissions in one place can be compensated by a tonne avoided or removed elsewhere. In principle the atmosphere does not care about location. In practice the difficulties are well documented: additionality, whether the reduction would have happened anyway; permanence, whether stored carbon stays stored; measurement, whether the claimed quantity is real; and double counting.

Avoided emissions credits and durable removal credits are not equivalent, and much of the criticism directed at corporate neutrality claims concerns reliance on the former. A company disclosing which type it purchased is telling you something. A company that does not is telling you something too.

05Reduction is the part that counts

The question worth asking of any carbon claim is what the absolute emissions were, whether they have fallen, and by how much. Compensation is accounting. Reduction is the physical change.

Manufacturers that are serious about this generally publish a reduction target, a baseline year and progress against it, and they distinguish reduction from compensation in their reporting. Manufacturers that are not serious put two words on a bottle. The difference is visible to anyone willing to look at a company's published reporting rather than at its packaging.

06Packaging is not the whole footprint

Consumer attention concentrates on packaging because packaging is visible and because waste is tangible. For many grooming products, though, ingredients and use phase dominate the carbon picture, while packaging dominates the waste picture.

Those are different environmental problems with different solutions, and conflating them produces poor decisions: switching to a heavier glass container can increase transport emissions while improving the recycling story. The comparison is worked through in glass, aluminium, plastic.

07Five questions that resolve most claims

1. What is inside the boundary? Operations only, or the full life cycle including raw materials and use.
2. What methodology was used, and was it independently verified?
3. What are the absolute emissions, and are they falling?
4. What type of offsets, and are they disclosed?
5. Is the claim about the product, the range or the company? These are routinely conflated.

If a company cannot answer these from published material, the claim is not assessable. That is not proof of bad faith, but it is a reason to give the claim no weight.

08Climate positive and other superlatives

Climate positive, net positive, carbon negative and nature positive have no standard definitions in this context. Regulatory guidance on environmental claims specifically identifies vague and absolute environmental language as a risk area, because such terms create an impression that cannot be substantiated.

Our default is to record these as unassessable rather than as false. We cannot say a claim is untrue when there is no definition against which to test it, and we can say that a term without a definition should not influence a purchase.

09What we do with carbon claims

In the transparency index we record whether a carbon claim is made, whether a boundary is stated, whether a methodology is named, whether absolute emissions and a reduction trajectory are published, and whether offset types are disclosed. A product with no carbon claim is not penalised, because silence is more informative than an unassessable claim.

We do not calculate footprints ourselves and we do not publish figures we cannot source, which means we describe what a company discloses rather than ranking companies on emissions. That is a limit of what a publication can do responsibly, and stating it is better than implying an authority we do not have. The full criteria are in how we assess.