{ "id": "sustainability-claims", "url": "https://coffearium.org/entries/sustainability-claims/", "license": "CC-BY-4.0", "title": "Sustainability claims and greenwashing rules", "summary": "What the EU rules applying from 27 September 2026 and the Swiss rules on climate claims say about environmental and sustainability claims on coffee bags, menus and websites, and how offsetting, insetting and carbon removal differ.", "domain": "sustainability", "kind": "Concept", "stage": "trade", "topics": [ "sustainability" ], "topicSections": { "sustainability": { "id": "what-counts-as-an-environmental-claim", "label": "What counts as an environmental claim" } }, "lang": "en", "status": "verified", "reviewer": "Coffearium verification pass", "lastVerified": "2026-10-14T00:00:00.000Z", "updated": "2026-10-14T00:00:00.000Z", "added": "2026-10-13T00:00:00.000Z", "brief": [ "The EU Directive on empowering consumers for the green transition (Directive (EU) 2024/825) applies through national laws from 27 September 2026.1,2", "Generic claims such as “eco-friendly” are banned in the EU unless the trader can show recognised excellent environmental performance relevant to the claim.1,2", "Claims that a product has a neutral, reduced or positive emissions impact because of offsetting are banned in the EU.1", "Sustainability labels must be based on a certification scheme or set by public authorities.1", "In Switzerland, climate claims must be backed by objective and verifiable evidence since 1 January 2025.4" ], "quickFacts": [ { "label": "EU law", "value": "Directive (EU) 2024/825, amending the Unfair Commercial Practices Directive 2005/29/EC" }, { "label": "Applies from", "value": "27 Sep 2026 (national laws; transposition deadline 27 Mar 2026)" }, { "label": "Scope", "value": "Business-to-consumer practices; business-to-business practices are outside it" }, { "label": "Green Claims Directive", "value": "Proposal only; withdrawal announced 20 Jun 2025; listed as pending in the Commission work programme for 2026; no formal withdrawal found (as of October 2026)" }, { "label": "Switzerland", "value": "Federal Act against Unfair Competition (UWG), Art. 3(1)(x), in force since 1 Jan 2025; federal guide on climate claims, 2 Mar 2026" }, { "label": "Not legal advice", "value": "This entry describes what the texts say, as of October 2026" } ], "aka": [ "Greenwashing rules", "Green claims", "Environmental claims", "Empowering Consumers Directive", "EmpCo" ], "linkTerms": [ "greenwashing", "green claims", "environmental claim", "generic environmental claim", "sustainability label", "carbon offsetting", "carbon insetting", "insetting", "climate neutral", "Directive 2024/825" ], "related": [ "sustainability-in-coffee", "carbon-footprint-of-coffee", "certifications-and-labels", "eudr", "packaging", "capsules-and-the-environment", "deforestation-and-coffee", "climate-change-and-coffee" ], "contested": [ "Permanence of land-based removals: the Intergovernmental Panel on Climate Change (IPCC) describes carbon stored in vegetation and soils as held for decades to centuries and more vulnerable than geological storage7; the GHG Protocol standard allows companies to report such removals if they monitor continued storage and account for reversals11; a 2026 study of the UK voluntary soil carbon market, citing earlier work, states that issues with additionality and permanence would likely prove persistent.8", "Company-level neutrality claims: in the EU, the offsetting ban in Annex I point 4c covers product claims, not company-level claims, which remain subject to the general rules on misleading practices2; the Swiss federal guide treats “climate neutral” as in practice not demonstrable for a company or a product and sets strict conditions for company-level CO₂-neutrality claims.4,5" ], "corrections": [], "sources": [ { "id": "s1", "title": "Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information", "year": 2024, "publisher": "Official Journal of the European Union, L series (EUR-Lex)", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202400825", "tier": "A", "quote": "Displaying a sustainability label that is not based on a certification scheme or not established by public authorities.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s2", "title": "Questions & Answers on Directive (EU) 2024/825 (Empowering Consumers for the Green Transition)", "authors": "European Commission, Directorate-General for Justice and Consumers", "year": 2026, "publisher": "European Commission, Brussels (September 2026)", "url": "https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_en?filename=faq-empowerting-consumers-gtd.pdf", "tier": "A", "tierNote": "A for what the Commission states; the document presents preliminary views of Commission services, not a legally binding interpretation", "quote": "The ECGT Directive shall apply from 27 September 2026.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s3", "title": "Substantiating and communicating green claims (Legislative Train Schedule, A European Green Deal)", "authors": "Ashton, D. (Members' Research Service)", "publisher": "European Parliament", "url": "https://www.europarl.europa.eu/legislative-train/theme-a-european-green-deal/file-substantiating-green-claims", "tier": "A", "quote": "On 20 June 2025, the Commission announced that it intends to withdraw the proposal.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s4", "title": "Vollzugshilfe zur Beurteilung von klimabezogenen Angaben im Sinne des UWG (Umwelt-Vollzug UV-2561)", "authors": "Bundesamt für Umwelt (BAFU)", "year": 2026, "publisher": "Federal Office for the Environment (FOEN), Bern", "url": "https://www.bafu.admin.ch/dam/de/sd-web/2A-QevWNsJQK/UV-2561%20Vollzugshilfe%20klimabezogene%20Angaben%20im%20Sinne%20des%20UWG_DE.pdf", "tier": "A", "quote": "Die genannten Bestimmungen traten am 1. Januar 2025 in Kraft.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s5", "title": "Klimabezogene Angaben – neue Vollzugshilfe schafft Rechtsicherheit (news release, 2 March 2026)", "authors": "Bundesamt für Umwelt (BAFU)", "year": 2026, "publisher": "Federal Office for the Environment (FOEN), Bern", "url": "https://www.bafu.admin.ch/de/vollzugshilfe-uwg", "tier": "A", "quote": "Der Begriff «klimaneutral» ist derzeit faktisch nicht nachweisbar und sollte nicht verwendet werden.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s6", "title": "EU Ecolabel – Product Groups and Criteria", "publisher": "European Commission, Directorate-General for Environment", "url": "https://environment.ec.europa.eu/topics/circular-economy-topics/oldeu-ecolabel/eu-ecolabel-product-groups-and-criteria_en", "tier": "A", "quote": "Based on the findings, the Commission is currently not intending to develop EU Ecolabel criteria for food and feed products.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s7", "title": "IPCC AR6 WGIII: CDR Factsheet", "authors": "Intergovernmental Panel on Climate Change, Working Group III", "publisher": "IPCC", "url": "https://www.ipcc.ch/report/ar6/wg3/downloads/outreach/IPCC_AR6_WGIII_Factsheet_CDR.pdf", "tier": "A", "quote": "CDR is not a substitute for deep emissions reductions", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s8", "title": "Soil Carbon Markets in the Making: Power Relations and Matters of Concern in Offsetting and Insetting", "authors": "Simmonds, P.; Ingram, J.; Maye, D.", "year": 2026, "publisher": "Environmental Policy and Governance (in press, published online 6 August 2026)", "url": "https://eprints.glos.ac.uk/16448/20/16448%20Simmonds%20%282026%29%20Soil%20carbon%20markets%20in%20the%20making%20published%20version.pdf", "doi": "10.1002/eet.70128", "tier": "A", "quote": "Insetting is at an experimental stage, with little consistency in approach between companies", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s9", "title": "Action needed to make carbon offsets from forest conservation work for climate change mitigation", "authors": "West, T. A. P.; Wunder, S.; Sills, E. O.; Börner, J.; Rifai, S. W.; Neidermeier, A. N.; Frey, G. P.; Kontoleon, A.", "year": 2023, "publisher": "Science 381(6660), 873–877", "url": "https://research.vu.nl/en/publications/action-needed-to-make-carbon-offsets-from-tropical-forest-conserv/", "doi": "10.1126/science.ade3535", "tier": "A", "quote": "We found that most projects have not significantly reduced deforestation.", "abstractOnly": true, "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s10", "title": "SBTi's Forest, Land and Agriculture (FLAG) Guidance in Brief, version 1.2 (March 2026)", "authors": "Science Based Targets initiative", "year": 2026, "publisher": "Science Based Targets initiative (SBTi)", "url": "https://files.sciencebasedtargets.org/production/files/SBTi-FLAG-Guidance-in-Brief.pdf", "tier": "A/B", "tierNote": "A for what the guidance requires of companies setting FLAG targets; B otherwise", "quote": "Offsets are not acceptable removals.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s11", "title": "Land Sector and Removals Standard, version 1.1 (Agriculture and CO2 removal technologies)", "authors": "Greenhouse Gas Protocol", "year": 2026, "publisher": "World Resources Institute and World Business Council for Sustainable Development", "url": "https://ghgprotocol.org/sites/default/files/2026-06/Land-Sector-and-Removals-Standard-v1.1.pdf", "tier": "A/B", "tierNote": "A for what the standard requires and its own publication and effective dates; B otherwise", "quote": "For removals, companies are required to establish physical traceability to the sourcing region, LMU, or harvested area", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s12", "title": "Sustainability strategies by companies in the global coffee sector", "authors": "Bager, S. L.; Lambin, E. F.", "year": 2020, "publisher": "Business Strategy and the Environment 29, 3555–3570", "url": "https://research.dial.uclouvain.be/bitstreams/e6a3caa8-5d36-4dcb-8ca2-cf79dc2e1455/download", "doi": "10.1002/bse.2596", "tier": "A", "quote": "A third of companies report no commitment to sustainability, whereas another third report vague commitment.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s13", "title": "New Guidance on Climate Claims under the Swiss Unfair Competition Act", "authors": "Pfisterer, S.; Allemann, R. G.; Bichsel, L.", "year": 2026, "publisher": "Homburger (law firm), Zurich", "url": "https://www.homburger.ch/en/insights/new-guidance-on-climate-claims-under-the-swiss-unfair-competition-act", "tier": "C", "tierNote": "Law-firm commentary; cited only next to the FOEN guide (source 4), never alone", "quote": "that cannot be substantiated on the basis of objective and verifiable criteria", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s14", "title": "Land Sector and Removals Standard (web page)", "authors": "Greenhouse Gas Protocol", "year": 2026, "publisher": "World Resources Institute and World Business Council for Sustainable Development", "url": "https://ghgprotocol.org/land-sector-and-removals-standard", "tier": "A/B", "tierNote": "A for the standard's own publication and effective dates; B otherwise", "quote": "The effective date of the standard is January 1, 2027.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s15", "title": "Digital Markets, Competition and Consumers Act 2024, Part 4, Chapter 1 (Protection from unfair trading)", "year": 2024, "publisher": "UK Parliament (legislation.gov.uk)", "url": "https://www.legislation.gov.uk/ukpga/2024/13/part/4/chapter/1", "tier": "A", "quote": "Unfair commercial practices are prohibited.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s16", "title": "The Digital Markets, Competition and Consumers Act 2024 (Commencement No. 2) Regulations 2025 (SI 2025/272)", "year": 2025, "publisher": "UK Government (legislation.gov.uk)", "url": "https://www.legislation.gov.uk/uksi/2025/272/made", "tier": "A", "quote": "Chapter 1 (protection from unfair trading) of Part 4 (consumer rights and disputes), except sections 232, 234 and 235", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s17", "title": "Digital Markets, Competition and Consumers Act 2024, Part 3, Chapter 4 – Infringement notices and penalties", "year": 2024, "publisher": "UK Parliament (legislation.gov.uk)", "url": "https://www.legislation.gov.uk/ukpga/2024/13/part/3/chapter/4/crossheading/infringement-notices-and-penalties", "tier": "A", "quote": "a fixed amount not exceeding £300,000 or, if higher, 10% of the total value of the turnover", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s18", "title": "Making environmental claims on goods and services (Green Claims Code)", "authors": "Competition and Markets Authority (CMA)", "year": 2021, "publisher": "GOV.UK", "url": "https://www.gov.uk/government/publications/green-claims-code-making-environmental-claims/environmental-claims-on-goods-and-services", "tier": "A", "tierNote": "A for what the regulator states; guidance on existing law, not law itself", "quote": "Claims must consider the full life cycle of the product or service", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s19", "title": "16 CFR 260.4 – General environmental benefit claims (Guides for the Use of Environmental Marketing Claims)", "publisher": "Electronic Code of Federal Regulations (eCFR), US Government", "url": "https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-260/section-260.4", "tier": "A", "quote": "Because it is highly unlikely that marketers can substantiate all reasonable interpretations of these claims, marketers should not make unqualified general environmental benefit claims.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s20", "title": "16 CFR 260.5 – Carbon offsets", "publisher": "Electronic Code of Federal Regulations (eCFR), US Government", "url": "https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-260/section-260.5", "tier": "A", "quote": "competent and reliable scientific and accounting methods", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s21", "title": "Guides for the Use of Environmental Marketing Claims; request for public comment (Federal Register 87(243), 20 December 2022)", "authors": "Federal Trade Commission", "year": 2022, "publisher": "Federal Register (govinfo.gov)", "url": "https://www.govinfo.gov/content/pkg/FR-2022-12-20/html/2022-27558.htm", "tier": "A", "quote": "As administrative interpretations of the law, the Guides themselves are not enforceable.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s22", "title": "Green Guides (rule page and history)", "authors": "Federal Trade Commission", "publisher": "Federal Trade Commission", "url": "https://www.ftc.gov/legal-library/browse/rules/green-guides", "tier": "A", "quote": "The Green Guides were issued to help marketers ensure that the claims they are making are true and substantiated.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s23", "title": "AB-1305 Voluntary carbon market disclosures (bill text)", "year": 2023, "publisher": "California Legislative Information (California Legislature)", "url": "https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240AB1305", "tier": "A", "quote": "shall disclose on the entity's internet website all of the following information pertaining to each project or program", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s24", "title": "2023 AB 1305 (Gabriel, Jesse): Voluntary carbon market disclosures – Chaptered (legislation tracking)", "year": 2023, "publisher": "California Air Resources Board (CARB)", "url": "https://ww2.arb.ca.gov/2023-ab-1305-gabriel-jesse-voluntary-carbon-market-disclosures-chaptered", "tier": "A", "quote": "Chaptered", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s25", "title": "Competition Act (R.S.C., 1985, c. C-34), section 74.01", "publisher": "Justice Laws Website, Department of Justice Canada", "url": "https://laws-lois.justice.gc.ca/eng/acts/C-34/section-74.01.html", "tier": "A", "quote": "not based on adequate and proper substantiation", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s26", "title": "C-15 (45-1): Budget 2025 Implementation Act, No. 1 (LEGISinfo)", "year": 2026, "publisher": "Parliament of Canada", "url": "https://www.parl.ca/legisinfo/en/bill/45-1/c-15", "tier": "A", "quote": "Statutes of Canada 2026, c. 3", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s27", "title": "Competition Act (R.S.C., 1985, c. C-34), section 74.1", "publisher": "Justice Laws Website, Department of Justice Canada", "url": "https://laws-lois.justice.gc.ca/eng/acts/C-34/section-74.1.html", "tier": "A", "quote": "$10,000,000 and, for each subsequent order, $15,000,000", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s28", "title": "Making environmental claims: A guide for business (December 2023)", "authors": "Australian Competition and Consumer Commission (ACCC)", "year": 2023, "publisher": "ACCC, Canberra", "url": "https://www.accc.gov.au/system/files/greenwashing-guidelines.pdf", "tier": "A", "tierNote": "A for what the regulator states; guidance on the Australian Consumer Law, not law itself", "quote": "Principle 5: Avoid broad and unqualified claims", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s29", "title": "Fines and penalties", "authors": "Australian Competition and Consumer Commission (ACCC)", "publisher": "ACCC", "url": "https://www.accc.gov.au/business/compliance-and-enforcement/fines-and-penalties", "tier": "A", "quote": "on or after 28 March 2026", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s30", "title": "Act against Unjustifiable Premiums and Misleading Representations (Act No. 134 of 1962), English translation", "publisher": "Japanese Law Translation, Ministry of Justice, Japan", "url": "https://www.japaneselawtranslation.go.jp/en/laws/view/2888", "tier": "A", "tierNote": "Official translation for reference; only the Japanese text has legal effect; translation reflects the Act as amended by Act No. 118 of 2014, later amendments not reflected", "quote": "equivalent to three percent of proceeds from sales", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s31", "title": "環境表示ガイドライン【令和8年3月版】 (Environmental Labelling Guidelines, March 2026 edition)", "authors": "環境省 (Ministry of the Environment, Japan)", "year": 2026, "publisher": "Ministry of the Environment, Tokyo", "url": "https://www.env.go.jp/policy/hozen/green/ecolabel/guideline/guideline.pdf", "tier": "A", "tierNote": "A for what the ministry states; guidance, not law", "quote": "令和 8 年 3 月にグリーン・ウォッシュ対策の国際的動向等を踏まえた改定を行いました。", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s32", "title": "中华人民共和国广告法 (Advertising Law of the People's Republic of China)", "publisher": "Central People's Government of the People's Republic of China (gov.cn)", "url": "https://www.gov.cn/guoqing/2021-10/29/content_5647620.htm", "tier": "A", "quote": "广告以虚假或者引人误解的内容欺骗、误导消费者的，构成虚假广告。", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s33", "title": "公平交易法 (Fair Trade Act)", "publisher": "Fair Trade Commission, Taiwan (law database)", "url": "https://law.ftc.gov.tw/law/LawContent.aspx?id=FL011898", "tier": "A", "quote": "事業不得在商品或廣告上，或以其他使公眾得知之方法，對於與商品相關而足以影響交易決定之事項，為虛偽不實或引人錯誤之表示或表徵。", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s34", "title": "Environmental Technology and Industry Support Act, English translation (as amended to Act No. 17183, 31 Mar 2020)", "publisher": "Korea Legislation Research Institute (Statutes of the Republic of Korea)", "url": "https://elaw.klri.re.kr/eng_mobile/viewer.do?hseq=54144&type=sogan&key=16", "tier": "A", "tierNote": "Government translation for reference; only the Korean text has legal effect; later amendments not reflected", "quote": "may impose a penalty surcharge not exceeding the amount equivalent to 2/100 of the turnover", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s35", "title": "Enforcement Decree of the Environmental Technology and Industry Support Act, English translation", "publisher": "Korea Legislation Research Institute (Statutes of the Republic of Korea)", "url": "https://elaw.klri.re.kr/eng_mobile/viewer.do?hseq=68242&type=part&key=39", "tier": "A", "tierNote": "Government translation for reference; only the Korean text has legal effect; text as amended to Presidential Decree No. 34657 (2 Jul 2024)", "quote": "The detailed types of unfair labeling and advertising under the subparagraphs of", "accessed": "2026-10-14T00:00:00.000Z" } ], "markdown": "## What counts as an environmental claim\n\nAn environmental claim is any voluntary message that states or implies that a product, brand or trader has a positive or zero environmental impact.1 It also covers messages that something is less damaging than others, or has improved over time.1 Text, images, symbols, brand names and spoken words all count.1,2 Information that the law requires is not an environmental claim.1\n\nGreenwashing is the everyday word for environmental claims that mislead. The EU and Switzerland do not ban claims as such. They ban claims that are vague, unproven or based on the wrong kind of evidence.1,4 The EU rules also cover social claims, such as fair working conditions or ethical commitments.2\n\nThe rules matter to the coffee trade because claims are common in it. In a 2020 study of 513 coffee companies, a third reported no commitment to sustainability and another third reported only vague commitment.12 The authors found indications of potential greenwashing by some companies.12\n\nThis entry describes what the legal texts and official guidance say, as of October 2026. It is not legal advice.\n\n## What the EU rules ban\n\nThe EU Directive on empowering consumers for the green transition is Directive (EU) 2024/825.1 It amends the Unfair Commercial Practices Directive, the EU's general law against misleading business-to-consumer practices.1 Member States had to adopt national rules by 27 March 2026 and apply them from 27 September 2026 (Article 4).1,2 According to the European Commission's questions-and-answers document, the directive provides no transition period beyond that date.2\n\nThe directive adds practices to the list of practices that are banned in all circumstances (Annex I).1 Four of them matter most for coffee:\n\n- **Generic environmental claims without proof of excellence.** A generic claim is a vague claim such as “eco-friendly”, “green” or “climate friendly”, with no specification on the same medium.1,2 It is banned unless the trader can show recognised excellent environmental performance relevant to the claim (point 4a).1\n- **Neutral or reduced impact through offsetting.** Claiming that a product has a neutral, reduced or positive greenhouse gas impact because of offsetting is banned (point 4c).1 The directive does not define offsetting; recital 12 refers to offsetting emissions outside the product's value chain.1\n- **Home-made sustainability labels.** A label that is not based on a certification scheme, and not set by a public authority, is banned (point 2a).1\n- **Future claims without a plan.** A claim about future environmental performance needs clear, verifiable commitments in a detailed, realistic implementation plan (Article 6(2)(d)).1 An independent third-party expert must check progress regularly.1,2\n\nTwo further bans concern the scope of a claim. A claim about the whole product or business is banned if it concerns only one aspect (point 4b).1 Presenting a legal requirement for all products in a category as a special feature is also banned (point 10a).1\n\nThe rules apply to dealings with consumers. Business-to-business practices, such as selling green coffee to a roaster, fall outside the directive.2 Member States may extend protection to them in national law.2\n\n### Claim checker\n\nThe table sorts common kinds of claims by the provision that governs them. The examples are generic and invented for illustration; they do not describe any real product or company.\n\n| Kind of claim (generic example) | EU, from 27 Sep 2026 | Provision (EU) | Switzerland, since 1 Jan 2025 |\n|---|---|---|---|\n| Vague claim with no specification (“eco-friendly coffee”, “planet-friendly blend”) | **Not allowed**, unless recognised excellent environmental performance is shown1,2 | Annex I point 4a | Treated as a climate claim where climate is a substantial part of the environmental impact; implies a significant reduction in emissions, which must be explained4 |\n| Same idea, specified on the same label (“the energy used to make this bag comes from renewable sources”) | **Allowed only if** true, clear and substantiated; it is then a specific claim, not a generic one2 | Art. 2 definitions; general rules against misleading claims | Must not be incorrect or misleading (Art. 3(1)(b) UWG)4 |\n| Product “climate neutral” or “CO₂-compensated” because credits were bought | **Not allowed**1,2 | Annex I point 4c | Product claims must not be based on compensation4,5 |\n| Product with a “reduced CO₂ impact” from cuts in its own value chain | **Allowed only if** based on the product's actual life-cycle impact and specified clearly and prominently on the same medium1,2 | Annex I point 4c; recital 12 | Allowed if emissions fell significantly and the reference point and size of the cut are stated4 |\n| Company claim (“our roastery is climate neutral”) based on credits | Not covered by point 4c; **allowed only if** not misleading under the general rules2 | Arts 6 and 7 of Directive 2005/29/EC | “Climate neutral” should not be used; company CO₂-neutrality only if hard-to-avoid emissions are fully balanced by negative emissions4,5 |\n| Statement that the company funds a carbon-credit project | **Allowed** if not misleading1,2 | Recital 12 | May be stated as a contribution, with its context explained; must not replace reductions in the value chain4 |\n| A seal the roaster designed itself (“responsibly sourced”) with no third-party scheme behind it | **Not allowed**1 | Annex I point 2a | A label can itself be a climate claim; otherwise the general rule against misleading claims applies4 |\n| Label of a certification scheme that meets the definition, or set by a public authority | **Allowed**1 | Annex I point 2a; Art. 2(r) | General rules apply4 |\n| “Sustainable coffee” when only the bag changed | **Not allowed**1 | Annex I point 4b | General rules apply4 |\n| “Net zero by 2035” | **Allowed only if** backed by a detailed, realistic plan with measurable, time-bound targets and regular independent checks1,2 | Art. 6(2)(d) of Directive 2005/29/EC | Must say clearly that it is a future target and rest on a reduction path in line with Swiss targets4 |\n| A legal duty for all coffee presented as a special feature | **Not allowed**1,2 | Annex I point 10a | General rules apply4 |\n| Green leaves or water drops on the packaging, next to sustainability statements | **May count** as a claim or as a label; the Commission advises caution2 | Art. 2 definitions; Annex I points 2a and 4a | General rules apply4 |\n\n“General rules apply” in the Swiss column means that no specific rule for this case appeared in the sources opened for this entry. A claim must then not be incorrect or misleading.4\n\n## What it means for bags, menus and websites\n\nThe directive covers any communication directly connected with promoting or selling a product to consumers.2 The Commission does not list channels. For a roaster or café, bags, shelf cards, menus, websites and social media posts that promote coffee fit this description. A mandatory sustainability report is usually outside its scope; reusing its content in consumer marketing brings it back in.2\n\nThe Commission names brand and product names as a risk. Terms such as “green”, “eco”, “natural” or “climate neutral” in a name may themselves be environmental claims.2 Artwork can also count. A green leaf or water drop next to sustainability statements may be read as a trust mark.2\n\nProducts already on the market are covered too. The Commission mentions stickers on old packaging and extra information at the point of sale as practical measures.2 Authorities and courts may consider whether a trader made reasonable and proportionate efforts.2\n\nCertification labels remain possible. The directive defines a certification scheme by four conditions.1 It must be open to all traders on fair terms, and developed with experts and stakeholders.1 It must also have procedures for non-compliance and independent third-party monitoring.1 The directive does not list which schemes meet these conditions. The certifications entry describes what each coffee scheme requires.\n\nOrganic terms follow their own law. The Commission states that terms from the EU organic regulation, such as “bio” and “eco”, can be used to show compliance with organic rules.2 This holds even though they could otherwise count as generic environmental claims.2\n\n## Switzerland\n\nThe FOEN guide notes that many Swiss companies also operate in the EU, and summarises EU law for them.4 The Commission states that the EU rules apply whether traders or products come from inside or outside the EU.2 A Swiss roaster selling to consumers in the EU is therefore subject to the EU rules there.2\n\nIn Switzerland, traders follow the Federal Act against Unfair Competition (UWG). Its general rule bans incorrect or misleading statements (Art. 3(1)(b)).4 Since 1 January 2025, a separate rule covers the climate (Art. 3(1)(x)). Claims about the climate impact of a company or its products must be backed by objective and verifiable evidence.4,13 It entered into force together with an amendment to the CO₂ Act (Art. 39(4bis)).4\n\nThe Federal Office for the Environment (FOEN, German BAFU) presented a guide on climate claims on 2 March 2026 (the document is dated January 2026).4,5 It states that “climate neutral” is in practice not demonstrable and should not be used.5 Product claims must not rest on compensation.4,5 For companies, compensation is possible only under strict conditions, with emission cuts first.5 The guide sets out how the authorities read the law; claims under the UWG are decided mainly by the civil courts.4\n\nThe Swiss rule targets climate claims, while the EU rules also cover other environmental and social claims.2,4 On product claims based on compensation, the two lead to the same result.1,4\n\n
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Dates of the EU and Swiss rules on environmental and climate claims, as of October 2026.1,2,3,4,5 The Green Claims proposal has not become law.
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\n\n## Around the world\n\nOutside the EU and Switzerland, most markets for coffee handle green claims through their general laws against misleading advertising. Some regulators add guidance on how they apply those laws to environmental claims. The table summarises the rules in force as of October 2026, with penalties where the law states them. “No claim-specific rule found” means that a search of official legislation and regulator sites found no rule written for environmental claims; the general ban on misleading advertising still applies. Like the rest of this entry, the table describes the texts and is not legal advice.\n\n| Jurisdiction | Rule | What it requires | Since / status (as of October 2026) |\n|---|---|---|---|\n| EU | Directive (EU) 2024/8251 | See “What the EU rules ban” above: bans on generic claims, offset-based product claims and self-made labels1 | Applies from 27 Sep 20261,2 |\n| Switzerland | Federal Act against Unfair Competition (UWG), Art. 3(1)(x); FOEN guide on climate claims4 | Climate claims need objective and verifiable evidence; product claims must not rest on compensation. See “Swiss rules in detail” below4 | In force since 1 Jan 2025; guide presented 2 Mar 20264,5 |\n| United Kingdom | Digital Markets, Competition and Consumers Act 2024, Part 4 Chapter 115; Competition and Markets Authority (CMA) guidance “Making environmental claims on goods and services”18 | Unfair and misleading commercial practices are banned.15 The CMA expects claims to be substantiated, to consider the full life cycle and to say whether emissions are reduced or offset18 | Act in force since 6 Apr 202516; CMA fines up to GBP 300,000 or 10% of turnover, if higher17; guidance first published 20 Sep 202118 |\n| United States (federal) | Federal Trade Commission (FTC) Act, section 5; FTC Green Guides, 16 CFR Part 26019,21 | No unqualified general environmental benefit claims19; carbon offsets measured with competent and reliable methods and not sold twice.20 The Guides are not enforceable themselves; the FTC must prove deception21 | Guides revised Oct 2012; review opened 20 Dec 2022; no revised Guides published as of October 202621,22 |\n| United States (California) | Voluntary carbon market disclosures (Assembly Bill 1305)23 | Entities claiming net zero or carbon neutrality must disclose on their website the offsets used, or how the claim was determined and progress is measured23 | Enacted (chaptered) in 202324 |\n| Canada | Competition Act, s. 74.01(1)(b.1) and (b.2)25 | Product claims of environmental or climate benefit need an adequate and proper test; business claims need adequate and proper substantiation. The person making the claim carries the burden of proof25 | Amended by Budget 2025 Implementation Act, No. 1 (royal assent 26 Mar 2026)25,26; penalties up to CAD 10 million (15 million for repeat orders) or, if higher, 3 times the benefit (3% of worldwide revenue if it cannot be determined)27 |\n| Australia | Australian Consumer Law, ss 18, 29, 33 and 34; Australian Competition and Consumer Commission (ACCC) guide “Making environmental claims”28 | Misleading conduct and representations are banned. The ACCC guide sets eight principles, including evidence for claims and no broad, unqualified claims such as “carbon neutral” without explanation28 | Guide December 202328; maximum per breach for companies AUD 100 million, 3 times the benefit or 30% of adjusted turnover, for conduct from 28 Mar 202629 |\n| Japan | Act against Unjustifiable Premiums and Misleading Representations (Act No. 134 of 1962)30; Ministry of the Environment, Environmental Labelling Guidelines (環境表示ガイドライン)31 | Misleading quality claims are banned; without requested evidence a claim is deemed misleading.30 The guidelines require an explanation with vague terms and own reductions before offsetting31 | Act in force; surcharge 3% of sales (English text as amended to 2014; later amendments not opened)30; guidelines revised March 2026 for greenwashing31 |\n| China | Advertising Law of the People's Republic of China (中华人民共和国广告法), Arts 4, 28 and 5532 | No claim-specific rule found (as of October 2026). Advertisements must not contain false or misleading content32 | Revised law in force since 1 Sep 2015, later amended; fines 3–5 times the advertising cost, or CNY 200,000–1 million if that cost cannot be calculated or is very low32 |\n| Taiwan | Fair Trade Act, Arts 21 and 4233 | No claim-specific rule found (as of October 2026). False or misleading representations on matters that affect purchase decisions are banned33 | Text as amended 14 Jun 2017; fines TWD 50,000–25 million, then TWD 100,000–50 million for each further order if the conduct continues33 |\n| South Korea | Environmental Technology and Industry Support Act, Art. 16-1034 | Manufacturers and sellers must not make false, exaggerated, deceptive, unfairly comparative or slanderous environmental claims.34 The Ministry of Environment may order verification and corrective advertising34,35 | In force; surcharge up to 2% of turnover (English text as amended to 31 Mar 2020; later amendments not opened)34 |\n\n## Offsetting, insetting and carbon removal\n\nThese three terms describe where an emission cut or a removal happens, and who counts it.\n\n- **Offsetting** means counting emission cuts or removals from outside the value chain against one's own emissions.1,4 These usually come as carbon credits, which are obtained and sold within defined standards.8\n- **Insetting** means that a company reduces emissions, or funds removals, within its own supply chain.8 In a 2026 study of the UK soil carbon market, agri-food businesses gave their main suppliers incentives to change farming practices.8 The study describes insetting as experimental, with little consistency between companies.8\n- **Carbon dioxide removal** means taking carbon dioxide out of the atmosphere and storing it durably.7 According to the IPCC, it is not a substitute for deep emission cuts.7\n\nFor coffee, insetting could mean shade trees planted on the farms that supply a roaster. The figure shows the difference that the EU rules draw.\n\n
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\n
    \n
  1. The product's value chain. From the supplying farm to the bag. A product claim must rest on the actual life-cycle impact of this chain.1,2
    2. \n
  2. Insetting. Emission cuts or removals that a company funds within its own supply chain, here shade trees on a supplying farm.8
    3. \n
  3. Stored carbon. Carbon held in vegetation and soils is stored for decades to centuries and is more vulnerable than geological storage.7
    4. \n
  4. A project outside the chain. Its carbon credits are traded within defined standards.8
    5. \n
  5. The credit assigned to the product. A neutral, reduced or positive impact claim for the product based on it is banned in the EU.1 Advertising the investment itself remains possible if not misleading.1,2
    6. \n
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Inside and outside a coffee's value chain, as the EU offsetting rule draws the line. Schematic, not to scale.
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\n\nThe Commission's guidance also mentions removals. Some biomass-based products can store more carbon dioxide than their value chain emits.2 A claim based on that must still rest on the product's actual life-cycle impact.2\n\nThe EU banned offset-based product claims as a matter of law, not on the basis of a single study.1 Research shows why the quality of credits is questioned. In a 2023 study of 26 forest-conservation project sites in six countries, most projects had not significantly reduced deforestation.9 For those that had, reductions were substantially lower than claimed.9\n\n\n\n## Key definitions in the directive\n\nDirective (EU) 2024/825 inserts new definitions into Article 2 of Directive 2005/29/EC.1 The bans in Annex I depend on them.\n\n| Term | What the directive says, in short | Article 2 of 2005/29/EC |\n|---|---|---|\n| Environmental claim | Any voluntary message or representation in a commercial communication that states or implies a positive or zero environmental impact, less damage than others, or improvement over time1 | (o) |\n| Generic environmental claim | An environmental claim not on a sustainability label, whose specification is not given clearly and prominently on the same medium1 | (p) |\n| Sustainability label | A voluntary trust mark or quality mark, public or private, that sets apart a product, process or business for its environmental or social characteristics; mandatory labels excluded1 | (q) |\n| Certification scheme | Third-party verification, open to all traders on fair terms, requirements developed with experts and stakeholders, procedures for non-compliance, independent monitoring1 | (r) |\n| Recognised excellent environmental performance | Performance compliant with the EU Ecolabel Regulation (EC) No 66/2010, an officially recognised EN ISO 14024 type I ecolabelling scheme, or top performance under other Union law1 | (s) |\n\n## Generic claims and coffee\n\nFor coffee, the exception in point 4a is narrow. The EU Ecolabel is one route to recognised excellent environmental performance.1 The Commission's EU Ecolabel page (accessed 13 October 2026) states that it is not intending to develop EU Ecolabel criteria for food and feed products.6 The other routes are national or regional type I ecolabels under EN ISO 14024, or top performance under other Union law.1 No study or official source opened for this entry names such a route for coffee.\n\nThe Commission also treats generic carbon-neutrality claims as generic environmental claims.2 They are therefore banned unless recognised excellent environmental performance is shown.2 If they rest on offsetting, point 4c bans them in any case.2\n\nA specified claim is not generic. The Commission gives “100% of energy used to produce this packaging comes from renewable sources” as an example of a specific claim.2 Whether such a claim is permitted depends on the circumstances.2 Specific claims remain subject to the general rules on misleading actions and omissions.1,2\n\nSector law takes precedence where it conflicts with the directive.2 The Commission applies this to organic terms under Regulation (EU) 2018/848.2\n\n## The offsetting rule in detail\n\nRecital 12 of the directive explains point 4c. Claims of a neutral, reduced or positive impact should only be allowed when they are based on the actual life-cycle impact of the product.1 They should not be based on offsetting greenhouse gas emissions outside the product's value chain.1 The same recital states that companies may still advertise their investments in environmental initiatives, including carbon credit projects.1\n\nThe Commission adds three points.2 First, point 4c does not apply to offsetting claims at company level; those remain subject to the other provisions of the Unfair Commercial Practices Directive.2 Second, a product may be described as having a “reduced CO₂ impact” if this is specified clearly and prominently on the same medium.2 Third, it cites the examples given in recital 12, such as “climate neutral”, “CO₂ neutral certified” and “carbon positive”.2\n\nThe Commission's document presents the preliminary views of its services. Only the Court of Justice of the EU can interpret EU law authoritatively.2\n\n## Future performance claims\n\nA claim such as “net zero by 2035” is a claim about future environmental performance. Article 6(2)(d) treats it as misleading unless four things are in place.1\n\n1. Clear, objective, publicly available and verifiable commitments.1\n2. A detailed and realistic implementation plan with measurable, time-bound targets.1\n3. Regular verification by an independent third-party expert.1\n4. The expert's findings made available to consumers.1\n\nThe Commission suggests annual or biennial reviews as good practice.2 The Swiss guide adds that a future claim must say clearly that it describes a future state.4 A net-zero target must also rest on an emission reduction path in line with Swiss climate targets.4\n\n## Swiss rules in detail\n\nArt. 3(1)(x) UWG makes it unfair to make climate-impact claims that cannot be substantiated by objective and verifiable evidence.4,13 According to the FOEN guide, this shifts the burden of proof to the company making the claim.4 The revised CO₂ Act (Art. 39(4bis)) also lets the FOEN provide the basis and standards for determining the climate impact of companies and products.4\n\nThe guide's main positions:4\n\n- “Climate neutral” is, as of 2026, in practice not demonstrable for a company or a product.4 “CO₂-neutral” and “greenhouse-gas-neutral” are in practice excluded for product claims.4\n- A company may claim CO₂-neutrality only if all its hard-to-avoid emissions are fully balanced by negative emissions.4\n- A company may state that it funds reductions outside its value chain as a contribution, without relating them to its own emissions. Such a contribution supports no further claim, and its context must be explained.4\n- Companies give priority to reductions within the company and its value chain.4 Certificates must not prevent, delay or replace those reductions.4\n- A certificate from abroad can support a claim such as “net zero” only if the host country has authorised transfer of the effect. This is the corresponding adjustment under Article 6 of the Paris Agreement.4\n- “Climate-friendly” and “CO₂-reduced” product claims need a clear explanation of their scope. They must not rest on compensation outside the value chain.4 A “CO₂-reduced” claim must state the reference point and the size of the reduction.4\n- Third-party verification before a claim is not required. A company that skips it carries the risk that the claim is found unfair.4\n\nEnforcement runs mainly through the civil courts.4 Competitors and consumer organisations can sue.4 The Confederation, represented by the State Secretariat for Economic Affairs (SECO), can sue where the economic interests of several people are affected.4 Intentional unfair conduct under Article 3 can also be prosecuted, on complaint, under Article 23 UWG.4 The Swiss Commission for Fairness in Commercial Communication, the industry's self-regulatory body, also judges cases.4\n\n## Accounting standards for removals\n\nTwo voluntary standards set out how companies may count land-based removals. Neither is law, and neither decides what a product label may say.\n\nThe Science Based Targets initiative (SBTi) guidance for forest, land and agriculture (FLAG) targets covers emissions and removals.10 It requires removals and emission reductions to be accounted for and reported separately.10 Removals count only within the boundaries of the FLAG target; the guidance states that offsets are not acceptable removals.10 It lists coffee among the commodities that drive deforestation.10\n\nThe Greenhouse Gas Protocol published its Land Sector and Removals Standard on 30 January 2026; it takes effect on 1 January 2027.14 Version 1.1, published on 30 June 2026, is the version to use, as of October 2026.11,14 It covers agriculture and CO₂ removal technologies; forestry is excluded from this version.11 Companies must report removals separately from emissions, by accounting category.11 For removals, companies must establish physical traceability to the sourcing region or harvested area.11 They must also monitor continued storage and account for reversals.11 Companies that report the impact of projects and interventions must report it separately from the physical inventory.11\n\n## Storage and permanence\n\nAccording to the IPCC, carbon stored in vegetation, buildings and soils is held for decades to centuries.7 In soils and sediments it can be held for centuries to millennia, and in geological formations for 10,000 years or more.7 Storage in vegetation, soils or sediments lasts for less time and can be more vulnerable.7 The IPCC's removal definition does not include natural removal, such as the growth of natural forests.7\n\nThis matters for coffee wherever insetting relies on trees and soils, as in the shade-tree example above. A 2026 study of the UK soil carbon market notes that insetting schemes have been critiqued for often lacking independent verification.8 Citing earlier work, the authors state that issues with additionality and permanence would likely prove persistent.8\n\n## The Green Claims proposal\n\nThe Commission adopted a proposal for a Green Claims Directive on 22 March 2023.3 It would have required explicit environmental claims to be based on an assessment, with verification before use by an accredited independent body.3 It also proposed a validation procedure for new private labelling schemes.3\n\nThe European Parliament adopted its first-reading position on 12 March 2024, and the Council its general approach on 17 June 2024.3 On 20 June 2025, the Commission announced that it intended to withdraw the proposal.3 The trilogue scheduled for 23 June 2025 was cancelled.3 The Commission's 2026 work programme, adopted on 21 October 2025, lists the proposal as pending.3 As of October 2026, no source opened for this entry records a formal withdrawal. The proposal is not law.\n\n## Company claims in the coffee sector\n\nA 2020 study coded the sustainability efforts of a random sample of 513 companies in the global coffee sector.12 A third reported tangible commitments, a third vague commitments and a third none.12 In that sample, 9% of the companies claimed to be “sustainable” while adopting only three or fewer sustainability practices and no external standard.12 The authors call for a transparent, mandatory reporting framework.12 The study predates the EU and Swiss rules described here.\n\n## Open questions\n\n- **Routes to recognised excellent performance for coffee.** The Commission is not intending to develop EU Ecolabel criteria for food, and no source opened for this entry names another recognised route for coffee.1,6\n- **Case law under the new rules.** As of October 2026, the Commission's guidance states preliminary views, and claims under the Swiss UWG are decided mainly by the civil courts.2,4 How courts read terms such as “recognised excellent environmental performance” is not yet established.\n- **Insetting claims on products.** Within-value-chain removals in coffee, such as shade trees, store carbon in vegetation and soils, where storage is shorter and more vulnerable than in geological formations.7 How such removals can support a product claim under the life-cycle rule is not settled in the sources opened.\n\n## Key studies\n\n
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West et al., 2023 – Forest-conservation offsets. Compared 26 forest-conservation project sites in six countries on three continents with synthetic control areas. Most projects had not significantly reduced deforestation, and those that had reduced it substantially less than claimed. The authors trace the gap to project baselines that did not match observed deforestation in the control areas.

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Science 381(6660), 873–877 · doi:10.1126/science.ade3535

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Bager & Lambin, 2020 – Sustainability strategies in coffee. Coded the sustainability practices of a random sample of 513 companies in the global coffee sector. Commitments split into thirds: none, vague and tangible. The authors found indications of potential greenwashing and called for common indicators and mandatory reporting.

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Business Strategy and the Environment 29, 3555–3570 · doi:10.1002/bse.2596

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Simmonds et al., 2026 – Offsetting and insetting in soil carbon. Studied how the UK voluntary soil carbon market is forming, through offsetting and insetting in agri-food supply chains, using 17 interviews and a validation workshop. They describe insetting as experimental and inconsistent between companies. Citing earlier work, they note criticism that insetting often lacks independent verification and that additionality and permanence remain open issues.

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Environmental Policy and Governance (early view) · doi:10.1002/eet.70128

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