Author: Rüdiger Meyer
The regulatory landscape for climate claims has changed fundamentally. With the EU’s new Empowering Consumers Directive (EmpCo), which will take effect on September 27, 2026, the era of vague “climate-neutral” advertising claims based on “simple offsetting” will come to an end. Green, misleading promises without scientific evidence will finally be a thing of the past.
What may seem like a limitation at first glance is, upon closer inspection, an enormous opportunity for companies that want their communications to be truly effective.
The New Reality: Why the Path Inevitably Leads to a Contribution Claim
Let's not kid ourselves: EmpCo is fundamentally changing the rules of the game. The days when products could simply be made “climate-neutral” by purchasing certificates are over—compensation claims at the product level are effectively dead.
Even for the company as a whole, such claims are now permissible only under the strictest conditions. Anyone who talks about offsetting today must present a comprehensive reduction strategy and may offset only those residual emissions that are absolutely unavoidable.
For most companies, however, the reality is that it will take years before all avoidable emissions are actually eliminated within their own operations and supply chains.
The logical consequence: the contribution claim—that is, the transparent disclosure of a company’s financial contribution to global climate protection —will remain the only viable and legally sound tool for companies for the foreseeable future.
Instead of claiming to have “neutralized” a negative impact, companies must now communicate the active role they play.
An example
Previously valid claims that were based solely on offsetting through the purchase of certificates and remained vague in their wording, such as “Our company is already climate-neutral” are under EmpCo only in a context that can be specifically substantiated. Starting in September 2026, for example, the statement would have to read “We have already reduced CO2 emissions in our production by XY% compared to 2020”.
This raises a strategic question: Which certificates do we use for the contribution claims required under EmpCo?
From a purely regulatory standpoint, ex-ante (forward) certificates are just as suitable for this purpose as ex-post certificates. Strategically and in terms of communication, however, they represent two very different approaches.
Ex-post certificates are often associated with traditional compensation claims, as they represent climate benefits that have already been achieved in the past. In other words, the climate impact has already occurred.
Ex-ante certificates , on the other hand, tell a whole new story: Anyone who buys ex-ante today is acting as a true “enabler”—companies are thereby financing and making possible climate protection projects that would never have seen the light of day without this upfront investment.
And this is exactly where eva certificates reveal their true value: Why finance anonymous projects on the other side of the world when the impact of an investment can be made directly tangible? With ex-ante certificates from eva, you invest in local forest ecosystems, support the urgent transition to climate-resilient mixed forests, and can continuously track the positive progress.
It’s important to note: Without this upfront investment in climate protection—right where employees go for walks on the weekend and customers are at home—there will be no impact on the climate!
Instead of abstract sponsorships, ex-ante local risk management and visible accountability take place right on our own doorstep.
The CFO Factor: Hedging—Today's Price for Tomorrow's Certificate
Every marketing department appreciates a compelling story. But the raw numbers are even more interesting to senior management and the finance department. The good news is that ex-ante is not just a communication strategy—it’s also an active hedging strategy.
According to the SBTi, most large corporations will be required to meet their net-zero targets by 2030. Starting at that point, analysts predict a massive excess demand for high-quality carbon removal credits. The Kopernikus Ariadne project at the Potsdam Institute for Climate Impact Research published a study in 2025 on the prices of ex-ante credits in 20301. Price scenarios ranging from well over 100 to 150 euros per metric ton are not uncommon.
So anyone who waits and buys allowances only after the fact in the future exposes themselves to enormous price risk in a market that has been completely depleted.
My conclusion, therefore, is this: EmpCo places immense value on ex-ante projects as strategic enablers. They are the most powerful tool companies have to credibly and regionally anchor their role as climate pioneers. What’s more, they serve as a financial shield. We aren’t making costly investments in the past; rather, we’re intelligently financing the solutions of tomorrow. That is precisely the story that credible and smart companies need to tell today.
Sources
1CO2 Prices Needed to Achieve the European …
