The European Green Deal is a pact that looks to improve the well-being and health of citizens and future generations by providing a range of basic necessities, such as fresh air, clean water, healthy soil, healthy and affordable food, cleaner energy, future-proof jobs, and much more.
It bases much of this on the European Union (EU) becoming greener. Recently, the European Commission released a series of new rules focused on corporate responsibility that aims to strengthen the path toward its carbon-neutral goal.
How will these changes affect life in the EU? We review the upcoming EU rules on green claims and greenwashing and what they mean.
What Is the European Green Deal policy?
The European Union (EU) and European Parliament recognize that climate change and environmental degradation threaten all life in Europe and worldwide. To help get past these challenges and improve the chances of a clean, safe world for future generations, all 27 EU Member States agreed to the European Green Deal.
This environmental agreement will help convert the EU into a modern, resource-efficient, and competitive economy by ensuring:
- A reduction in net greenhouse gas emissions by 55% of 1990 levels by 2030
- Zero greenhouse gas emissions (GHG emissions) by 2050
- Economic growth becomes decoupled from resource use
- No person or place is left behind economically or ecologically
- EU’s energy independence
- Job creation and growth
- An improvement in the overall health and well-being of EU citizens
Financing for the European Green Deal will come from dipping into one-third of the 1.8 trillion euro ($2.022 trillion) investments from the NextGenerationEU Recovery Plan and the EU’s seven-year budget.
What Is the New EU Environmental Legislation?
Newly proposed legislation for the European Green Deal focuses heavily on green claims. Green claims are any claim an organization makes that it’s taking action to combat GHG emissions and to help slow climate change.
Currently, EU laws don’t regulate environmental claims, which leads to inconsistencies with regard to the handling of these claims among Member States.
The changes would also better define green claims. They would be defined as: “any message or representation, which is not mandatory under Union law or national law, including text, pictorial, graphic or symbolic representation, in any form, including labels, brand names, company names or product names, in the context of a commercial communication, which states or implies that a product or trader has a positive or no impact on the environment or is less damaging to the environment than other products or traders, respectively, or has improved their impact over time.”
This is all in an attempt to prevent greenwashing — when an organization focuses more on marketing itself as environmentally friendly than minimizing its environmental impact.
Let’s review the main proposed changes.
Rules for Methodology
To help ensure all green claims are valid and harmonious across the EU, EU Member States must validate environmental claims through science-based methodologies.
Accepted methodologies are expected to have to follow these basic guidelines:
- They must be based on widely recognized scientific evidence and state-of-the-art technical knowledge and account for relevant international standards. Claims are not allowed if no recognized scientific method exists or there’s insufficient evidence to assess environmental impacts and aspects.
- They must assess environmental impact throughout the product’s life cycle.
- They must account for the composition of products, the materials they use when producing products, the amount of emissions created during production, the use of the product, and the product’s durability, reparability, and end-of-life aspects.
- They must assess if achieving positive environmental impacts, aspects, or performance significantly increases any other negative environmental impact.
- They must be third-party accessible with a reasonable access fee, if applicable.
- They require regular review from a third party that can account for technical and scientific progress and the development of relevant international standards.
Rules on Green Claims
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So, what will be considered valid green claims under these proposed rules? While nothing is official yet, the green claims directives will be as follows:
- They can only make environmental claims substantiated through an approved methodology that meets specific criteria, which we’ll cover later.
- They cannot make positive environmental claims if a product has a positive and negative environmental impact. They may publicize the positive claim, but they must also communicate the negative impact clearly and understandably.
- They must make the information on the assessment on which the environmental claim is based available
With regard to the final bullet point, the information on the assessment that should be made available includes:
- Information about the product or activities of the trader subject to the claim; Environmental aspects, environmental impacts, or environmental performance the claim covers
- Methodology used
- Underlying studies or calculations they used to analyze, measure, and monitor the claim’s environmental impact
- A brief explanation of how they improved environmental performance via a weblink, QR code, or equivalent
There also needs to be a review of the accuracy of their environmental claims every five years at minimum.
Rules on Comparative Environmental Claims
Organizations can make comparative environmental claims as a part of marketing efforts, but experts anticipate the new rules to crack down on such claims. Some of the proposals include:
- Organizations must utilize the identical methodology as the products or traders they compare themselves to.
- Organizations must generate or source the data to substantiate comparative claims equivalently to ensure comparability.
- Organizations must account for the most significant stages along the value chain for all products and traders compared.
Rules on Forward-Looking Claims
Organizations may also claim anticipated environmental benefits under the newly proposed green claims directive. However, authorities would require these future-looking claims to follow specific guidelines, including:
- They must include commitments and milestones that they need to achieve within clearly specified time frames.
- They must indicate a baseline year for all targets, the desired result compared to the baseline year, and the target year to achieve the claim. For example, they might say something like, “We commit to making a 50% reduction in emissions by 2035 compared to our 1990 levels.”
- They cannot include previously achieved targets.
Rules on Enforcement
The proposed rules will also include how they will expose non-compliant organizations. In the proposed rules, public authorities would require Member States to perform compliance monitoring:
- As part of their regular checks
- In cases where they have sufficient reason to believe an environmental claim may infringe upon the rules
- If complaints arise
If an organization makes non-compliant environmental claims, the proposed rule changes would require it to fix the issues quickly. Once the organization receives a non-compliance notification, it would have 10 business days to respond with substantiation.
If the organization doesn’t provide a timely or satisfactory answer, regulatory officials will require it to modify the offending claim or cease all communication of it immediately as consumer protection. The trader will have 30 business days to implement corrective actions.
This enforcement aims to ensure all environmental labels and claims are credible and trustworthy, allowing consumers to make more educated purchasing decisions.
What Are the Current EU Environmental Policies?
The current European Green Deal may not be as extensive as the proposed regulation changes. However, it still looks to take on climate change and help prevent the potential global existential crisis it causes.
To help with this, the European Commission has adopted many climate-focused initiatives and policies, such as:
- Reducing car emissions by 55% by 2030
- Reducing van emissions by 50% by 2030
- Reducing all new-car emissions to 0% by 2035
- Performing energy-efficiency-improving renovations on 35 million buildings by 2030
- Reaching 40% renewable energy by 2030
- Reaching 36% to 39% energy efficiency by 2030
- Restoring Europe’s forests, soils, wetlands, and peatlands to increase carbon absorption to 310 megatonnes (Mt)
What Is the New EU Sustainability Directive?
The EU requires large companies and all listed companies — listed micro-enterprises are excluded — to disclose what they view as risks and opportunities associated with social and environmental issues. They must also disclose their activities’ impact on people and the environment.
This disclosure helps investors, civil society organizations, consumers, and other stakeholders evaluate companies’ sustainability performance as part of the European Green Deal.
In January 2023, the new Corporate Sustainability Reporting Directive (CSRD) was enacted. This new directive modernizes and strengthens the social and environmental information companies must report. A broader set of large companies and listed SMEs — approximately 50,000 companies — must now report on sustainability.
To be affected by this new reporting directive, a company must meet at least two of the three following criteria: employ 250-plus people, have assets totaling at least 20 million euros, and have turnover totaling at least 40 million euros.
Companies will begin applying the new reporting rules in the 2024 financial year for reports published in 2025. Until then, the current Non-Financial Reporting Directive (NFRD) national law will remain in force, requiring affected organizations to report on environmental protection (Scope 3 emissions included), social responsibility, the treatment of employees, human rights, anti-bribery and anti-corruption, and company board diversity.
Once the Corporate Sustainability Reporting Directive (CSRD) begins in 2024, corporations will have to report on all information in the current NFRD plus:
- Double materiality, including the company’s sustainability and climate risk, and the impact the company has on society and the environment
- Material-topic-selection process for stakeholders
- More forward-looking information, including organizational climate targets and its progress toward the targets
- Information regarding intangible items, including social, human, and intellectual matters
- Reports aligning with the Sustainable Finance Disclosure Regulation (SFDR) and European Union’s Taxonomy Regulation
Upcoming EU Rules on Green Claims Seek to Elevate Corporate Responsibility
To accelerate the battle against climate change and global warming, the EU continues updating policies and proposals to the existing European Green Deal. The latest proposals focus on empowering European organizations to improve their climate-neutral reporting and to make this a common practice among more European companies.
These upcoming EU rules on green claims and greenwashing may help Europe get on track and remain on a path to help reverse climate change. You can also do your part to help this process by offsetting your carbon footprint by purchasing voluntary carbon credit from Terrapass. We offer a wide range of options for businesses and individuals.
Choose the right option for you, and start offsetting your carbon footprint today.
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Carbon Footprint
Climate-Linked Supply Chain Risk Is Already in Your P&L
The earnings calls that quietly reframed climate from sustainability question to operating risk.
Three earnings calls in the last 18 months tell the story without any help from a press release.
Hershey, May 2024: cocoa price exposure compresses margin, and the company attributes part of the cost shock to West African weather. Olam, July 2024: coffee climate exposure quantified in the annual report. JBS, January 2025: supply chain climate disclosures expanded materially in response to investor pressure and regulatory expectation. None of these companies issued the announcement as climate news. They issued it as financial news. The climate-linked supply chain risk did not arrive with a sustainability framing; it arrived as a P&L line.
You are probably reading this article because you suspect the same thing is happening to your business. This piece walks through what is showing up on which earnings calls, how procurement and finance leaders are quantifying the exposure, and what serious corporates are doing about it before the regulator asks.
Where climate risk has already appeared in earnings
The pattern is consistent across resource-intensive sectors. A weather event compresses supply, the price spikes, the cost flows through the income statement, and the analyst on the call asks whether the event is anomalous or structural. Increasingly, the honest answer is the second one.
Cocoa is the cleanest example. The 2023 to 2024 West African harvest fell sharply on the back of erratic rainfall and disease. Cocoa futures more than tripled. Companies with concentrated West African sourcing absorbed the cost; companies with diversified sourcing absorbed less. The exposure was not climate as ESG topic. It was climate as cost of goods.
Coffee follows the same pattern. Brazilian and Vietnamese harvests have moved on weather more sharply across the last several seasons. Roasters with long-tenor supplier relationships and origin diversification have managed the volatility; roasters with spot-market exposure have not. Wheat, sugar, palm oil, beef: the same dynamic in different commodities, a pattern the IPCC AR6 Working Group II report projects will intensify across agricultural systems through mid-century.
What this means: climate risk is no longer a footnote in the 10-K. It is a line item the CFO has to explain on the call.
The three commodity exposures that hit margin first
For most companies with material Scope 3 exposure, three exposures dominate the near-term P&L risk.
- Concentrated single-origin sourcing in a climate-vulnerable region. If your tier-one supply for any material commodity sits in one geography, you have a concentration risk that climate amplifies. Diversification across origins is the obvious hedge, but it takes years to build and requires relationships you cannot acquire by tender.
- Supplier financial fragility under climate stress. Smallholder farmers, who supply a large share of the global cocoa, coffee, and palm oil market, do not carry the balance sheets to absorb yield shocks. When yields collapse, they exit. When they exit, your supply base shrinks, and the surviving suppliers raise prices. The risk is structural, not cyclical.
- Logistics and storage exposure to extreme weather. Hurricane disruptions to Gulf shipping, drought-driven Panama Canal restrictions, flooding in European inland waterways: each of these has moved input costs in the last three years, a pattern documented in Munich Re’s natural catastrophe data. The exposure shows up as a one-quarter event in the financial press but accumulates over time on the cost line.
TCFD and ISSB disclosure changes
The disclosure architecture has now caught up with the risk. The Task Force on Climate-related Financial Disclosures, whose recommendations are now embedded in the ISSB’s IFRS S2 climate standard, requires companies to disclose climate-related risks across physical and transition categories, with quantification where possible.
For physical risk specifically (the climate-linked supply chain risk you are reading about), the disclosure must address both acute exposures (extreme weather events) and chronic exposures (gradual changes in temperature, precipitation, and growing seasons). The disclosure must address the time horizon over which the risk is material, the parts of the value chain exposed, and the financial impact under different scenarios.
The CSRD imposes similar requirements under European law, with double materiality (both financial and impact materiality) embedded in the assessment. The practical effect: your auditors and your investor relations team now need a defensible answer to the climate-linked supply chain risk question, and the answer needs to be quantified.
What procurement and finance can do now
Three actions matter near-term.
Map your exposure. Most companies do not have a clear view of which tier-one and tier-two suppliers sit in which climate-vulnerable geographies. Without the map, you cannot quantify the risk, and without the quantification, you cannot disclose it credibly. The map is the foundation, and World Resources Institute climate risk research provides useful public tooling to start.
Diversify and deepen, in that order. Diversification across origins reduces concentration risk, but the deeper move is to invest in the resilience of the suppliers you already have. Regenerative practices, agroforestry, soil health interventions: these reduce yield volatility under climate stress and protect your input cost trajectory.
Embed the climate spend inside procurement, not outside it. Treating climate risk as a sustainability cost line subordinates it to the ESG budget. Treating it as a procurement and resilience investment puts it in the budget that matters, which is the cost-of-goods budget that the CFO defends quarterly.
Nature-based supply chain investments are the asset class designed for exactly this purpose. They sit inside the value chain, they reduce climate-linked supply risk, they generate verifiable Scope 3 reductions, and they produce the documentation an auditor and a regulator can both test.
If you are quantifying climate-linked supply chain risk in advance of the next earnings cycle or the next disclosure period, the carbon and sustainability experts at Carbon Credit Capital can help you map your exposure and structure a Dual-Value Model response that addresses reduction, resilience, and disclosure-readiness in a single program. Schedule a consultation.
Carbon Footprint
Where should an SME start with a carbon action plan?
More and more small and medium-sized businesses are hearing the same question from their larger customers: What is your carbon footprint? That question now travels down entire supply chains, and it arrives next to tender requirements, certification criteria, and rising customer expectations.
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Carbon Footprint
Insetting vs Offsetting: Which Actually Counts Toward Your Scope 3 Targets
The accounting differences that decide whether your nature investment shows up in inventory, in BVCM, or nowhere at all.
The question reaches a procurement team about three weeks before the next sustainability committee meeting. Someone has read about insetting. Someone else has just signed off on an offset purchase. The CSO wants to know if the two are interchangeable. The answer is no, and the GHG Protocol Land Sector and Removals Standard is the reason why.
This article walks through what each term means at audit-grade specificity, what the standards actually say about how each gets counted, and how to decide which tool fits which target. The insetting vs offsetting question is one of the most-searched in corporate climate strategy, and one of the most poorly answered. By the end of this piece, you should be able to brief a committee on the difference without notes.
The two definitions, in plain English
Offsetting means buying carbon credits generated outside your value chain and retiring them against your residual emissions. The reduction happens somewhere else, financed by you, and the credit is the receipt.
Insetting means investing in emission reductions or removals inside your own value chain, typically with suppliers, where the reduction is directly linked to the products and services you buy. The reduction happens inside the boundary of your Scope 3 inventory, and the accounting treatment is fundamentally different.
The shorthand from the University of Oxford’s Nature-based Insetting Initiative is useful: insetting is what you do with the supply chain you have; offsetting is what you do with the supply chain you do not have.
What the GHG Protocol Land Sector Standard actually says
The GHG Protocol Land Sector and Removals Standard, finalised in 2024 after a multi-year pilot, sets the rules for how land-based emission reductions and removals enter corporate inventories. The Standard distinguishes between inventory accounting (Scope 1, 2, and 3) and project or intervention accounting (a separate methodology for crediting).
For insetting, the practical implication is that supplier-level interventions, when properly measured and attributed, can reduce your Scope 3 category 1 (purchased goods and services) emissions in your inventory. The reduction is not a credit retired against the inventory; it is a lower inventory number, period.
For offsetting, the credit is retired separately. It can be reported as a contribution toward a net-zero claim under the SBTi Beyond Value Chain Mitigation framework or as part of a VCMI Carbon Integrity claim, but it does not lower the inventory number.
A practical consequence: if your Science Based Target requires a 50% absolute reduction in Scope 3 emissions by 2030, insetting moves you toward the target. Offsetting does not. This single point of difference reshapes the procurement decision.
When insetting counts toward Scope 3 (and when it does not)
Insetting counts toward Scope 3 only when several conditions are met:
- The intervention must occur with an entity in your value chain.
- The emissions reduction or removal must be measured against a defensible baseline.
- The reduction must be attributed to your share of that supplier’s output, not double-counted with other buyers.
- It must follow the inventory accounting rules in the GHG Protocol Land Sector Standard, not the project accounting rules used to generate credits.
The most common failure mode is double counting. If your supplier sells the same reduction as a credit on the voluntary market and also reports it to you as a Scope 3 reduction, the math breaks. The Standard requires you to address this risk, typically by purchasing and retiring the supplier-issued credit as part of your inventory or by contractual provisions that prevent the supplier from selling the reduction twice.
When insetting does not count toward Scope 3: when the intervention sits with a supplier you do not buy from, when the baseline is not defensible, when the attribution is unclear, or when the documentation does not survive audit. Those cases default to Beyond Value Chain Mitigation, which is still useful but operates on a different ledger.
The procurement and supplier engagement question
Insetting is harder than offsetting. That is the unfashionable truth most buyers eventually confront. Offsetting is a transaction; insetting is a relationship.
To run an insetting program, you need supplier mapping precise enough to know which farms or facilities sit at which Scope 3 boundary. You need an engagement model that gets suppliers to participate, which usually requires multi-year commitments and shared economics. You need an MRV architecture that measures the right things and produces audit-ready documentation. And you need a contractual structure that prevents double counting and protects both sides.
The trade-off you receive in return is significant. Reductions count against your inventory rather than your residual. Supplier relationships deepen, which protects sourcing continuity. Yield and quality improvements often follow regenerative interventions, which reduces your input cost over time. And the regulatory file, under CSRD, CSDDD, EUDR, and the SBTi FLAG Guidance, is materially stronger.
Choosing the right tool for the right target
A practical decision rule. If your target is a science-based Scope 3 reduction and you operate in a FLAG sector or source FLAG commodities, insetting is the structurally correct tool. If your target is a net-zero claim that includes neutralising hard-to-abate residual emissions outside your value chain, BVCM via high-integrity offsets is the structurally correct tool. Most companies with material Scope 3 exposure need both, in different proportions, sequenced over time.
The sequencing matters. Insetting takes longer to stand up but produces a permanent reduction in the inventory. Offsetting can be transacted faster but does not change the inventory and now sits under tighter claim restrictions. Treat them as complementary tools with different jobs, not as substitutes. The Accountability Framework Initiative and the IUCN Global Standard for Nature-based Solutions both provide useful guardrails for the insetting side, with biodiversity, human rights, and benefit-sharing requirements that go beyond carbon math.
If you are mapping a Scope 3 reduction roadmap and need to scope which interventions count toward your inventory versus which sit in Beyond Value Chain Mitigation, the carbon and sustainability experts at Carbon Credit Capital can help you structure a nature-based supply chain investment program that fits your FLAG exposure, your target architecture, and your audit horizon. Schedule a consultation.
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