What the regulators actually say
Two sets of guidance matter for a UK business talking about net zero.
The CMA's Green Claims Code sets six principles for environmental claims, including that claims must be truthful and accurate, clear and unambiguous, and substantiated. On targets it is specific: claims about future goals "should only be used for marketing purposes if the business has a clear and verifiable strategy to deliver them", and claims about a business's ambitions "must also be in proportion to its actual efforts". It adds that claims are less likely to mislead when they rest on specific, shorter term, measurable commitments the business is actively working towards.
The ASA and CAP guidance on carbon neutral and net zero claims, published in February 2023, says advertisers should avoid unqualified "carbon neutral" or "net zero" claims, should say whether and how far they are actually cutting emissions or relying on offsetting, should base claims about future net zero goals on a verifiable strategy, and should name any offsetting scheme they use. The ASA's own consumer research found people tended to assume "carbon neutral" meant emissions had actually been cut, and felt misled when offsetting was revealed.
Since April 2025 the stakes are higher. Under the Digital Markets, Competition and Consumers Act 2024, the CMA can decide for itself that consumer law has been broken and fine a business up to 10% of its global turnover. The wider rules on green claims and offsets are in our carbon offsetting guide, and our post on what the Green Claims Code means for small business marketing covers claims beyond targets.
Wording that causes trouble, and what to say instead
| Risky | Why | Safer |
|---|---|---|
| "We're a net zero business" | Unqualified, and suggests the work is already done | "We've committed to net zero by 2040 across Scope 1, 2 and 3. Read our plan." |
| "Net zero by 2030" | Doesn't say what is covered or how you'll get there | "We aim to cut our Scope 1 and 2 emissions by 50% by 2030 from our 2024 baseline, mainly by moving our vans to electric." |
| "Carbon neutral since 2024" | Usually rests on offsets, which the ASA says you must explain | "In 2025 we emitted [x] tonnes CO2e. We also funded [x] tonnes of [named scheme] credits, which don't count towards our reduction target." |
| "Science-based net zero target" | Implies outside validation you may not have | Only use the phrase if the target has been validated, and say by whom. |
| "Our emissions fell 20% this year" | May be mostly a change in the government's factors, not your doing | "Our emissions fell 20%. About [x] points of that came from cleaner grid electricity; the rest from [actions]." |
The figures in the "safer" column are placeholders. Use your own, and keep the evidence for each one.
What a verifiable strategy looks like
For a small business, "clear and verifiable" doesn't need a consultant's report. It needs a few facts that someone else could check:
- A measured baseline. A full year of emissions, with the scopes covered and the government factor year stated. Our post on picking a baseline year helps.
- A target with a boundary. Which scopes, absolute or per unit, and the year. An absolute target is the clearer claim.
- Named actions with dates. "Replace two diesel vans in 2027" is verifiable. "Explore greener options" is not.
- Yearly progress. Publish the figure each year, even when it goes up, and explain why.
A PPN 006 Carbon Reduction Plan already contains all four, signed by a director and published on your website. Linking a marketing claim to that plan is the simplest way to back it up.
A worked example: progress that isn't yours
An easy way for an honest firm to overstate progress is by claiming a fall in the government's conversion factors as its own work. A business uses exactly the same 40,000 kWh of electricity and 60,000 kWh of gas in two years in a row:
| Factor set | Electricity factor | Gas factor | Scope 1 and 2, tCO2e |
|---|---|---|---|
| 2025 | 0.177 | 0.18296 | 18.06 |
| 2026 | 0.13096 | 0.18231 | 16.18 |
Reported emissions fall by about 10% with no change in what the business did. Saying "we cut our emissions by 10%" would risk breaching the Green Claims Code's first principle: it's factually correct, but it gives the wrong impression. Report the figure, and say that it reflects a cleaner grid. Why your footprint dropped in 2026 explains the change in detail.
Before you publish a net zero claim
- Can you point to the measured baseline and the factor year behind it?
- Does the wording say which scopes the target covers, and by when?
- Is the explanation next to the claim, or one click away, as the Code expects?
- Have you separated real reductions from factor changes and from any offsets?
- Would the claim still be fair if a journalist read your plan alongside it?
If the answer to any of these is no, soften the claim to what you can show today. Our post on net zero, carbon neutral and climate positive explains what each term means, and the net zero guide for small businesses sets out a plan you can stand behind.
How Carbon Recycling helps
Carbon Recycling's Carbon Reduction Plan report states your baseline year, your reduction target as a percentage and a year, the pathway to it, and your completed and planned reduction projects, and it says in writing that carbon offsets are not counted towards the reductions shown. Every figure carries the government factor and year behind it, so when a factor change moves your total you can see it and say so. The plan is the evidence your net zero wording should link to. If you aren't measuring yet, start with the free kWh to CO2e calculator.