Carbon offsetting has been the default corporate climate move for more than a decade. Here is what changed: “offset” is now a contested word. In the US, the FTC Green Guides scrutinise unqualified offset and neutrality claims. The UK CMA has been enforcing its Green Claims Code, and can fine for breaches. The EU ECGT directive 2024/825 restricts vague environmental marketing from September 2026, and that reaches US companies selling into Europe. If carbon offsetting sits on your CSR roadmap, the more useful question is no longer “how do we compensate,” it is “what can we actually claim, and how do we evidence it.” You can scan your sustainability copy free to see where your current wording stands. This guide covers what the rules require, what credible companies do instead, and the exact phrases to retire.
Short answer: carbon offsetting is still legal, but the language around it is not safe by default. Regulators now expect a claim that is specific, substantiated and not misleading. The lowest-risk model is a contribution claim: fund real climate work, report exactly what you funded, and stop asserting that anything has been cancelled out.
Key Takeaways
- Offset and neutrality claims carry real legal risk under US FTC, UK CMA and EU ECGT rules. The wording matters as much as the activity.
- Contribution claims (“we funded verified reforestation”) are far more defensible than compensation claims (a product that “cancels out” emissions).
- Every claim needs a number and a source you can hand to a regulator, a journalist or a procurement team.
- ForestNation plants verified trees in Tanzania with field-measured CO2 data: 0.025 tonnes per tree per year, with a 30% uncertainty discount applied. That is a contribution to reforestation, and we do not describe it as more than that.
- Retire the risky phrases first. You can check your sustainability copy free before a regulator or a competitor does it for you.
What is carbon offsetting, and what changed?
For years, carbon offsetting meant buying credits to compensate for emissions a business could not yet cut. The model has not disappeared, but the way you are allowed to talk about it has narrowed sharply. Regulators in three major markets have moved against vague or unsubstantiated environmental claims, and offset language sits right in the firing line, because it implies a precise, like-for-like cancellation of emissions that is difficult to prove.
The practical shift for CSR teams is from compensation language to contribution language. Instead of claiming that a product or a company is neutral, credible organisations describe a specific, measurable thing they fund: trees planted, hectares restored, livelihoods supported. It is a smaller claim on paper. It is a far stronger one in front of anyone who asks you to prove it.
What do the FTC, CMA and ECGT require?
The three frameworks differ in detail but agree on the principle: an environmental claim must be specific, substantiated, and not misleading.
The US FTC Green Guides require that general environmental benefit claims be backed by competent and reliable evidence, and warn against broad terms a reasonable consumer cannot verify. The UK CMA Green Claims Code sets six tests, including that claims be truthful, clear and substantiated, with the regulator now able to fine for breaches. The EU ECGT directive 2024/825 goes further, restricting generic environmental terms and unsubstantiated future-looking claims across the bloc from September 2026.
None of this stops you doing real climate work. It stops you describing it loosely. The businesses that will be comfortable are the ones whose claims point at something they can show.
What to stop saying, and what to say instead
Most of the risk on a CSR page is carried by a handful of phrases. Swapping them is cheap, and it usually makes the claim more persuasive, because a specific number beats a slogan.
- Instead of “a carbon neutral company”, say “we cut emissions by 18% and funded the planting of 5,000 verified trees.” One is an assertion. The other is a report.
- Instead of “offset your footprint with every purchase”, say “every purchase funds a tree, planted and tracked in Tanzania.” You are describing what happens, not what it cancels.
- Instead of “eco-friendly” or “100% sustainable”, name the attribute you can evidence: the material, the process, the number.
- Instead of “we are helping save the planet”, state the thing you actually did, at the scale you actually did it.
For a fast read on where your own copy sits, GreenClaim.ai will scan your claims free and flag the phrases most likely to draw a challenge under the three frameworks.
Contribution beats compensation
A contribution-based reforestation programme answers the regulators directly. Rather than asserting that a purchase cancels a footprint, you fund the planting and stewardship of real trees, and you report exactly what was planted and where. The claim becomes “we funded the planting of 5,000 verified trees in Tanzania this year,” which is checkable, rather than “we are neutral,” which is not.
ForestNation is built for this. We plant verified trees in Tanzania with field-measured CO2 data, drawn from a study of GPS-tagged trees across five planting sites. The headline figure is 0.025 tonnes of CO2 per tree per year, with a deliberate 30% uncertainty discount applied so the number is conservative rather than flattering. You can read the full field-measured methodology. This is data you can put into a CSR report and stand behind. It is a contribution to verified reforestation. It is not a carbon credit, and we do not sell it as one.
Where carbon credits fit
Carbon credits and contribution claims are not the same thing, and the difference matters when you write the claim. A retired credit is a tradeable instrument issued against a verified project, and it is the only mechanism that supports a compensation claim at all, assuming the credit itself holds up. A contribution funds the work and reports the work, and makes no cancellation claim. If your team is weighing the credit route, our guide to forest carbon credits for companies covers how they are issued, what they cost, and where the quality risk sits.
How does a reforestation contribution strengthen CSR?
Beyond compliance, a real planting programme does work across the business. It gives marketing a story that holds up. It gives HR something employees are proud of, which feeds engagement. And it gives sales a credential that increasingly appears in tender questionnaires, where buyers now ask suppliers to evidence their environmental contribution rather than take it on trust.
There is a commercial case too. Reducing energy use lowers cost. Avoiding penalties protects margin. And a credible, evidenced programme is becoming a tiebreaker in competitive bids. You can start your tree planting programme and get a named company forest with a tree count that reconciles.
What does a credible programme look like in practice?
Take events. Happily, an events company, builds tree planting into the experiences it produces, and its forest has now passed 100,000 trees. The point is not a slogan on a website. It is a repeatable mechanic that produces a real, reportable number at the end of the year.
The same logic scales to product and procurement. A tree per order, a tree per sale, a forest per campaign: each one turns an intention into a count. ForestNation has worked with more than 500 companies, including clients such as Marriott, Logitech, Salesforce and Oracle, and has planted close to 2 million trees. The mechanic is simple on purpose. You decide what triggers a tree, we plant and track it, and you report what actually happened.
Fixing the claims you already have
If your site already uses offset or neutrality language, the safest next step is to audit the wording before someone else does. Swap compensation claims for contribution claims, attach a number and a source to each one, and link to the evidence. For the wider picture on positioning a sustainability story credibly, see our guide to green marketing strategies and our breakdown of green claims compliance.
Frequently asked questions
What is carbon offsetting for business?
Carbon offsetting is the practice of funding an external climate project, such as reforestation or renewable energy, to compensate for emissions a business has not yet cut. The activity is still legal and still common. What has changed is the language: regulators in the US, UK and EU now challenge claims that a purchase or a company has been made neutral, because that is a precise claim and it is hard to evidence.
Is it still legal to say your business offsets its carbon?
There is no blanket ban, but the claim has to be substantiated. The US FTC Green Guides require competent and reliable evidence for environmental benefit claims. The UK CMA Green Claims Code applies six tests, and the regulator can fine for breaches. The EU ECGT directive 2024/825 restricts generic and unsubstantiated environmental marketing from September 2026. If you cannot show the working behind the claim, do not make it.
What should a business say instead of carbon neutral?
Describe what you actually funded, with a number and a source. A contribution claim such as “we funded the planting of 5,000 verified trees in Tanzania this year” is checkable. A compensation claim such as “our product is neutral” invites a challenge you may not be able to answer.
What is the difference between a carbon offset and a contribution?
An offset asserts a like-for-like cancellation of a specific quantity of emissions, usually through a retired carbon credit. A contribution funds climate work and reports what was funded, without claiming to cancel anything out. Contribution claims are far easier to substantiate, which is why a growing number of CSR teams have moved to them.
Conclusion
Carbon offsetting is not dead, but the loose language around it is. The businesses that come through this regulatory shift in good shape will be the ones that made a smaller, sharper, evidenced claim and could prove it. A verified reforestation contribution, tracked tree by tree, is one of the cleanest ways to do that. It gives you a real story, a real number, and a CSR programme that reads as credible because it is.
Research and References
- FTC Green Guides, Guides for the Use of Environmental Marketing Claims, US Federal Trade Commission
- Green Claims Code, making environmental claims, UK Competition and Markets Authority
- Directive (EU) 2024/825 on empowering consumers for the green transition, EUR-Lex
- ForestNation impact methodology, the field-measured CO2 study behind the 0.025 tonnes per tree per year figure