'Climate Neutral by 2030': Why Future Promises Now Need a Plan

Under the current UWG, an environmental claim about a future environmental performance can be misleading if it is not backed by clear, objective, publicly accessible, and verifiable commitments. A detailed and realistic implementation plan is required, which must include measurable and time-bound targets and account for the relevant resources. In addition, the rules call for regular review by an independent external expert, with the findings made accessible to consumers.

Previously, the sequence was often: set a target, publish a press release, update the website, and only then develop the actual measures. Going forward, the order should typically be reversed: establish the current baseline, define the target, develop the measures, allocate resources, set interim milestones, assign responsibilities, organise an independent review — and only then communicate.

A standalone claim such as 'We will be net zero by 2030' would be problematic on its own. A more defensible version, provided it matches the actual plan, might read, purely as a hypothetical illustration: 'We aim to reduce our operational emissions in [a named scope] by [a specified percentage] by 2030 compared with a 2024 baseline. Our action plan includes [named measures]. Progress is reviewed [by a named method or party].'

A new technology might become available. The company might grow. The supply chain might shift. A good climate plan does not need to pretend it can perfectly predict the next ten years — but it must credibly show how the company currently expects to reach its target, and that plan must be kept up to date as circumstances change.

An internal target is initially something different from an advertising statement. But once it is used prominently on product pages, marketing materials, or campaigns, it becomes part of the company's commercial communication — and the company should assume the promise can and will be scrutinised. The decisive question is: could we credibly explain to a critical outsider, today, why we believe we can actually meet this target? If the answer is no, it is probably not just the claim that is premature. The plan itself may not yet be developed enough either.

EmpCo primarily complements the rules for commercial practices directed at consumers. Check the applicable national implementation separately; Germany’s UWG does not automatically govern claims in other countries. Precise wording alone does not replace matching evidence or a responsible person’s decision before publication. Review the overall impression, including the heading, image and immediately visible explanation. Automated findings do not approve a claim.