New Rules: How to Implement and Communicate Climate Strategy for Companies
2023 was a big year for climate action. We saw major announcements of new global governance and regulations across the world:
- In the US, California passed SB-253 Climate Corporate Data Accountability Act and AB-1305 Voluntary carbon market disclosures.
- In Europe, the European Commission released its Proposal for a Directive on Green Claims.
- Globally, new rules for the quality and use of carbon credits were issued ICVCM (The Integrity Council for the Voluntary Carbon Market) and VCMI (The Voluntary Carbon Markets Integrity Initiative), both receiving significant praise from global leaders at the most recent COP28.
At Terrapass, we’re excited by these developments. The world recognizes the need to significantly scale all climate solutions including voluntary carbon markets. For this we must have globally aligned standards. This came together on multiple fronts in 2023.
So, what does this mean for sustainability professionals and everyday consumers?
For everyday consumers this is great news. These regulations ensure that any climate accomplishments promoted by a business will be supported with details that clearly show how those claims were achieved. The rules also ensure that companies are actively working to reduce their own carbon emissions in addition to offsetting their remaining emissions. Please visit Terrapass for more information about your personal or small business carbon footprint.
For sustainability professionals the list of new rules and regulations might seem daunting, but it is also good news. This is a sign of a maturing industry. Policy and consumer experts are contributing their expertise to help make climate action impactful and understandable to both sustainability professionals and everyday customers.
Historically, professional sustainability terms like carbon neutral and net-zero often made their way into marketing and product messaging. Consumer advocates rightly recognized that everyday customers can’t evaluate these phrases on their own. Additionally, vague phrases like green, eco, and sustainable are often used to promote sustainability without any supporting information. Consumer advocates also recognized that customers must be able to see why a product is green. These new regulations in California and Europe ensure that climate communications are always factual and transparent. They ensure that companies can promote their sustainability accomplishments with confidence and that customers have information to evaluate those accomplishments.
New global governance, VCMI in particular, ensures that companies apply sustainability solutions in the most effective way. Terrapass has long promoted the principle of 1. Calculate, 2. Conserve, and 3. Offset in our sustainability guidance to customers. This approach prioritizes:
- First, understand where carbon emissions are in your business,
- Second, disclose your plan to reduce the carbon emissions of your business and regularly report progress, and
- Third, balance your remaining emissions with carbon credits that fund global emission reduction projects.
When companies describe their climate strategy, they sometimes combine these different elements into one term like “carbon neutral.” Phrases like this do reflect an important environmental achievement. However, they hide the distinction between your company’s emission reductions vs. global emission reductions funded through carbon credits. Emission reduction and offsetting must be separate elements of your sustainability strategy and they should also be separate elements of your climate communications. Key elements for your climate communications include:
Steps and priorities:
- Measure your carbon emissions, reduce emissions on a science-based trajectory, and disclose your progress publicly.
- Address your remaining emissions by funding high-quality carbon credits that help reduce greenhouse gases globally.
Tell two different stories in your climate communications:
- Business Emission Reduction: Our carbon footprint was 5,000 mT in 2023, a reduction of 500 mT vs. 2021 and 5% ahead of plan.
- Global Climate Contribution: We purchased 5,000 mT of carbon credits in 2023 to fund global carbon reductions equal to our remaining emissions.
Other considerations:
- Climate communications should be factual, specific and detailed; provide evidence of all environmental claims made.
- Talk about carbon credits as a way to balance your remaining emissions by funding global carbon reduction.
- Talk about carbon credits as a way to support other global sustainability goals (UN SDGs) when applicable.
- Avoid using vague, generic terms like green, eco, climate friendly, sustainable, etc. that are not substantiated.
- Avoid terms that combine your company’s emission reduction and carbon offsetting into one phrase like carbon neutral, climate neutral, etc.
Highlights from each of the new rules and regulations are provided below. Please contact a Terrapass sustainability advisor to help your company navigate its specific needs.
California SB-253 Climate Corporate Data Accountability Act
- For entities with total annual revenues in excess of $1,000,000,000 that do business in California:
- Starting in 2026: Report Scope 1 and Scope 2 greenhouse gas emissions
- Starting in 2027: Report Scope 3 greenhouse gas emissions
- Other requirements:
- For the reporting entity’s prior fiscal year
- Reporting is due annually on a date to be determined by the state board.
- Reporting follows the Greenhouse Gas Protocol
- Reporting entity must obtain an assurance engagement, performed by an independent third-party assurance provider, of the entity’s public disclosure as provided.
California AB-1305 Voluntary Carbon Market Disclosures
- Entities operating in California and making climate-related claims:
- Must publicly disclose information documenting how the claim was determined to be accurate or accomplished, and the measurement of interim progress.
- Applies to claims of net-zero emissions, carbon neutrality or similar, as well as claims of significant reductions in greenhouse gas (“GHG”) emissions,
- Entities operating in California and using voluntary carbon credits to support a climate-related claim.
- Must publicly disclose detailed information related to the credits purchased, the underlying offset projects and any independent verification of the climate-related claims made.
EU Green Claims Directive
- Applies to EU companies and non-EU companies making environmental claims aimed at EU consumers.
- Aims to eliminate greenwashing across EU markets by setting out detailed rules for how companies should market their environmental impacts and performance. It targets “vague, misleading or unfounded information on products’ environmental characteristics. “
- The current list of commercial practices that are banned in the EU is updated to include generic environmental claims – such as ‘environmentally friendly’, ‘natural’, ‘biodegradable’, ‘climate neutral’ or ‘eco’ – unless they can be properly evidenced.
- On the use of carbon credits specifically, the Green Claims Directive allows companies to make “carbon neutral” claims supported by carbon credits, but only if the carbon credits are disclosed correctly:
- Clearly state that carbon credits are being used to offset emissions.
- Disclose sources of emissions and amounts addressed with carbon credits.
- Identify carbon offset project types and distinguish between Reduction and removal offsets (requested, not required)
ICVCM (The Integrity Council for the Voluntary Carbon Market)
- New global quality standards for voluntary carbon credit projects; “regulatory-like”
- Program will be fully implemented over the course of 2023-2024.
- Rules for each carbon credit Category (Methodology/Project Type) were released in June 2023
- CCP-Eligible Programs (Registries) and CCP-Approved Categories (Project Types) will be announced in 2024.
- Not a one-time rule, standards will continuously evolve.
- First revision process for the CCPs in 2025, aimed at implementation starting in 2026.
- ICVCM points to VCMI for guidance on how businesses should use carbon credits.
VCMI (The Voluntary Carbon Markets Integrity Initiative)
- VCMI was established in 2021 to help ensure that voluntary carbon markets make a significant, measurable, and positive contribution to achieving the Paris Agreement goals.
- The VCMI Claims Code addresses market integrity on the demand side by guiding companies on:
- How they can credibly make voluntary use of carbon credits as part of their climate commitments, and
- The associated claims they can make regarding the use of those credits.
- The VCMI program should be followed together with ICVCM rules for high-integrity carbon credits.
Note: The above article provides introductory information only. Every organization must independently evaluate these rules and regulations, and determine specific actions needed for its own compliance.
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Written By Sam Tellen
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Carbon Footprint
Designing an Insetting Program: A Step-by-Step Playbook for Procurement
Insetting program design starts with your supplier map. The carbon claim comes much later.
Consider a coffee procurement team that funds a farm intervention before checking its sourcing data. The supplier aggregates coffee lots from several regions. The buyer lacks farm-level traceability. Another purchaser expects to report the same outcome. A more attractive project brochure solves none of these problems.
If the distinction between a value-chain intervention and a purchased credit is still open, read CCC’s Insetting vs Offsetting guide before you set the brief.
Insetting program design begins with the purchasing relationship and works outward. You need to decide 1) where an intervention belongs, 2) what business problem it addresses, 3) who pays for it, 4) how results will be measured, and 5) what the evidence will let you say about them. This five-step playbook turns that sequence into a procurement plan.
Step 1: Insetting program design starts with supplier mapping
Start with the commodities that matter most to your Scope 3 inventory and sourcing continuity. Ask finance for spend by supplier, sustainability for the emissions baseline, and category managers for origin and volume records. Then identify which suppliers can trace material to a jurisdiction, sourcing region, producer group, or individual land-management unit.
The level of traceability affects what you can account for. Under the GHG Protocol Land Sector and Removals Standard, the spatial boundary for purchased land-based products depends on the traceability associated with each volume. Farm-specific factors or removals require physical traceability through an acceptable chain-of-custody model. A contract with a tier-one trader, by itself, does not establish a link to the farms behind its deliveries.[1]
Build a first-pass table with five columns: commodity and annual volume; supplier and origin; current traceability level; land-use and production risks; and the business owner who can change the purchasing terms. Mark missing data plainly. A blank cell is cheaper to fix before a program starts than after a claim is drafted.
If your company sets an SBTi Forest, Land and Agriculture target (FLAG), keep its land-related target boundary separate from energy and industry emissions. The current FLAG guidance also requires relevant companies to assess primary deforestation-linked commodities in their value chains.[2]
Step 2: Choose a commodity and jurisdiction for a pilot
Select one supply corridor where the sourcing connection can be established and procurement has a reason to stay. A useful pilot has repeat purchases, suppliers willing to share records, an intervention matched to a diagnosed problem, and a defined plan to measure the result. Carbon potential alone is a poor selection rule if the supplier cannot deliver the crop your business needs.
Compare candidate regions on land-use risk, supplier concentration, local rights and tenure, the availability of baseline data, and exposure to drought, erosion, or forest conversion. Check the relevant legal requirements separately. A nature project does not satisfy a due-diligence obligation merely because it has a carbon method attached.
Consider a coffee buyer sourcing from two districts. In the first, producer-group records identify the farms, while recent dry seasons have increased rejected green coffee lots. In the second, deliveries pass through several intermediaries and farm origins are unknown. Pilot shade management in the first district, with local agronomic advice and quality checks built into the plan. The buyer can trace purchases there and test the intervention against a defined sourcing problem.
Use a short decision memo to record why the selected corridor beats the alternatives, what remains uncertain, and what would stop the pilot. That memo is the first control against a project drifting toward whatever happens to photograph well.
Step 3: Design the supplier engagement and commercial model
The intervention needs an owner on each side of the contract. Decide who supplies planting material or training, who maintains the practice, who bears the cost if a harvest disappoints, and how long the buyer expects to purchase from participating suppliers. Where smallholders participate, budget cash flow and technical support for practices that offer a later return.
Put these terms in a supplier agreement or pilot addendum. It should cover eligible farms and volumes, consent to data collection, access for monitoring, any land or carbon rights that matter, benefit sharing, and what happens if the purchasing relationship ends. Ask local counsel and producer representatives to review the arrangement. The Accountability Framework is a useful reference for supply-chain work involving forests, ecosystems, and human rights.[3]
Avoid assigning an automatic carbon benefit to the buyer. The contract should say which party has the right to report each outcome, how overlapping claims will be checked, and how any issued credits will be handled. A reduction reported in a buyer’s inventory cannot simply be sold for someone else’s offset claim without an accounting review. SBTi FLAG guidance excludes purchased credits used as offsets from near-term FLAG target achievement.[2]
Set commercial measures beside environmental ones: delivered volume, rejection rate, supplier retention, and procurement cost. They tell you whether the program works as a supply-chain investment, even if carbon accounting takes longer to resolve.
Step 4: Build monitoring, reporting, and verification before rollout
Agree on the baseline and data flow before paying for a full rollout. Identify the land units or sourcing regions in scope, the practices that change, the records suppliers already keep, and the additional measurements the program requires. Decide which data can come from field visits, transaction records, or remote sensing, and who checks each source.
For carbon, separate three questions. Did the practice happen? Did emissions or removals change under an applicable method? Can the buyer attribute a defensible share to its purchased goods without double counting? The GHG Protocol’s 2026 guidance includes dedicated chapters on spatial boundaries, data and methods, evaluating actions, credited outcomes, and assurance.[1] These are distinct jobs. A photograph of a planted tree answers only part of the first.
CCC’s MRV and Additionality article explains the separate evidence questions a project reviewer will ask.
Create an evidence file for every reporting period: dated supplier and farm records, purchase volumes, methods and emission factors, uncertainty, quality checks, and changes from the baseline. Specify who can challenge the data and how corrections are recorded. If a project also seeks credit certification, keep project accounting and corporate inventory accounting separate. The GHG Protocol says its land standard focuses on entity-level inventories and does not set the rules for credit certification.[4]
Start with the minimum viable measurement design that can survive review. Add complexity when the pilot tells you which data actually changes a decision.
Step 5: Decide what can be reported and claimed
Insetting program design needs reporting rules before the marketing copy. Procurement, sustainability, finance, and legal should agree on four distinct outputs: operational performance; observed land or nature outcomes; inventory effects, if the accounting criteria are met; and any separately issued credits. One dashboard can display them, but they should not share a single unqualified headline.
SBTi FLAG guidance allows certain land-based removals within a company’s operations or supply chain to contribute to FLAG pathways, subject to criteria including permanence, traceability, data quality, and allocation. It does not allow purchased offsets to meet near-term FLAG targets.[2] Eligibility therefore depends on evidence and the applicable target rules, not on calling an activity “insetting.”
Draft a claims register. For each proposed sentence, record the period, boundary, data owner, calculation method, reviewer, and whether the result is measured, estimated, or still a goal. If the evidence supports only “we funded a pilot with 200 farms,” say that. Do not turn a funding fact into a verified emissions reduction.
What good looks like by year three
Treat year three as a review point, not a promised payback date. A mature pilot should have mapped participating supply volumes, a stable supplier agreement, a repeatable data collection process, and a comparison of commercial and environmental results against the baseline. It should also have a documented answer for outcomes that cannot be included in the buyer’s inventory.
Scale only where the pilot improves a sourcing decision and the evidence can follow the product. If neither condition holds, redesign the intervention or change the corridor. A disciplined program can conclude that a site is unsuitable. That is useful procurement intelligence.
Discuss your insetting program with CCC
Carbon Credit Capital designs nature-based supply chain investments around sourcing needs and measurable sustainability outcomes. Schedule a consultation with our carbon and sustainability experts to map your tier-one supplier network, FLAG exposure, and first pilot decision.
Sources
[1] GHG Protocol, Land Sector and Removals Standard, version 1.1, and companion Guidance, June 2026: https://ghgprotocol.org/land-sector-and-removals-standard ; https://ghgprotocol.org/land-sector-and-removals-guidance
[2] Science Based Targets initiative, Forest, Land and Agriculture Science-Based Target-Setting Guidance, version 1.2, March 2026, especially pp. 16–17, 37, and 41: https://sciencebasedtargets.org/resources/files/SBTiFLAGGuidance.pdf
[3] Accountability Framework initiative, Accountability Framework and guidance for companies: https://accountability-framework.org/
[4] GHG Protocol, Frequently Asked Questions: Land Sector and Removals Standard, questions 10 and 18: https://ghgprotocol.org/blog/frequently-asked-questions-land-sector-and-removals-lsr-standard
Carbon Footprint
The Strategic Case for Nature-Based Carbon Investments
Nature-based carbon investments deserve consideration when they address a specific business dependency and produce outcomes you can measure. Imagine Moonbucks, a global coffee roaster planning next season’s espresso blend. It is considering natural Grade 4 coffee from Jimma, in southwestern Oromia, Ethiopia. Its sourcing decisions affect the roasting schedule and the cash tied up in coffee purchases. Moonbucks needs to understand which measures could protect that supply, what they would cost and how it would judge the results.
1. Define the sourcing problem before choosing a project
Moonbucks needs a dependable component for its espresso blend. Its procurement team wants continuity of volume and an agreed cup profile. Replacing a shipment at short notice could require new sample approval and changes to the blend, and given the schedules for cultivation, processing, and freight delivery, is practically impossible. Moonbucks needs to get this right, and its initial concern is inconsistent deliveries. It commissions an assessment of the supplying farms and post-harvest chain. The questions cover land condition, harvest availability and whether drying or storage problems are affecting saleable lots.
This distinction changes the investment brief. A tree-planting proposal cannot be assumed to fix drying problems. Better storage cannot restore eroded land. The team must establish which problem exists before selecting the response.
CCC’s guide to finding nature-based solutions in your supply chain explains where to look. Here, the next task is to turn a broad concern into a testable proposal.
2. Develop nature-based carbon investments around the actual supply chain
The assessment would trace Moonbucks’ purchases back through the exporter and supplying producer groups. Which farms supply the contracted lots? Who controls land-management decisions? How long does the buyer expect to maintain the purchasing relationship?
Furthermore, Jimma natural Grade 4 cannot be treated as interchangeable with every Ethiopian coffee. Moonbucks would need to test any substitute against its own blend and quality requirements.
Suppose Moonbucks’ assessment identifies an opportunity to maintain shade trees and restore vegetation along exposed streambanks. The IPCC describes agroforestry as a way to store carbon in vegetation and soil, with potential benefits for erosion control and water quality.1 Moonbucks would need local advice on species, growing conditions and maintenance before deciding how these measures fit its sourcing plan.
The proposal now has a defined sourcing connection and a candidate intervention. The next steps are to test its effect on production, assess carbon eligibility and build the financial case.
3. Compare the proposal with other ways to protect supply
WBCSD’s Nature-based Solutions Blueprint recommends comparing nature-based options with other responses across their benefits and costs.2 For Moonbucks, that means evaluating the landscape proposal alongside drying improvements, storage controls and alternative sourcing arrangements.
The product’s natural-process designation matters. Moonbucks should examine the drying and dry-milling chain alongside land conditions. Its team would check storage practices, contamination risks and incoming-lot quality to see whether problems arise before or after the coffee leaves the farms.
The revised proposal might combine land stewardship with separate post-harvest controls. Each component needs its own purpose and budget. A sustainability label should not obscure which activity is expected to solve which problem.
The project develops as the evidence improves. Its scope should follow the diagnosis rather than preserve the first idea unchanged.
4. Establish what the carbon outcome could count toward
Moonbucks’ sustainability team now tests the proposed carbon case separately from the sourcing case. Is the objective a measurable change in Moonbucks’ value-chain emissions, verified credits for separate voluntary use, or distinct outcomes under carefully defined arrangements?
Scope 3 covers value-chain emissions. A purchasing relationship alone does not prove that a farm intervention can be included in Moonbucks’ inventory. The team needs an applicable accounting method, defensible boundaries and evidence supporting attribution.
SBTi’s FLAG Guidance (forest, land and agriculture), version 1.2, says purchased credits used as offsets cannot meet near-term FLAG or energy and industry targets. Eligible land-based removals are subject to accounting requirements.3 Moonbucks needs to test its proposal against those rules before including an outcome in its targets.
For Moonbucks’ Jimma proposal, maintaining existing trees and establishing new vegetation could involve different carbon questions. Specialists must examine the baseline and additionality, meaning what changes because the project proceeds. They must also assess measurement and the risk that stored carbon is lost. CCC’s MRV and additionality article introduces those tests.
Until that work is complete, Moonbucks should not budget an assumed Scope 3 reduction or credit-sale receipt. Direct emissions reductions remain the priority.
5. Build a financial case that survives weaker assumptions
Moonbucks’ finance team would now build a multi-year budget. UNEP’s State of Finance for Nature 2023 compares current finance with the investment needed to meet climate, biodiversity and land-restoration goals.4 The company would cost its proposed activities, farmer participation and ongoing monitoring. Verification, where required, is a separate expense. Maintenance and responsibility for replacing failed plantings must remain visible after the initial establishment budget ends.
Operational benefits need equally careful treatment. If fewer rejected lots reduce emergency purchasing, count that saving once. Do not add “supply resilience” as another financial benefit when it represents the same avoided cost.
Moonbucks should compare a base case with slower benefits, higher implementation costs and no carbon revenue. It should also distinguish production outcomes from quality and shipment outcomes. A single good harvest would not prove that the landscape intervention caused better delivery performance.
A project can remain worth funding even when its carbon case needs more work. That decision must rest on the operational evidence and the company’s objectives, without unsupported environmental claims.
6. Fund a pilot with a clear expansion decision
Moonbucks’ first approval would fund a bounded pilot, rather than commit the entire sourcing program. Before spending, Moonbucks would agree on participating farms, responsibilities and the evidence needed at review.
Its scorecard could track farmer participation, implementation costs and plant survival, alongside accepted coffee volumes and lot-quality results. Carbon measurements would follow the selected method. Farm-level traceability must connect the intervention to the actual sourcing relationship.
Suppose Moonbucks’ review later finds that storage changes explain most quali

