‘Carbon neutral’ has become one of the most contested phrases in sustainability marketing. Regulators are tightening what the term can mean, courts are ruling against companies that use it loosely and the businesses still relying on it are finding that a calculated number is not the same thing as a defensible claim. What separates a credible carbon neutral supply chain claim from a risky one is accurate third-party verification.
1. Why Carbon Neutral Claims Are Under Pressure
From 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive bans product-level claims to consumers that a product has a neutral, reduced or positive climate impact where that claim rests on offsetting rather than genuine reductions in the value chain. The UK is moving in the same direction, and, importantly, setting a requirement that applies to all actors, regardless of whether they operate in B2C or B2B markets. The Competition and Markets Authority’s January 2026 guidance makes clear that all businesses are responsible for misleading environmental claims anywhere in their supply chain, not only the claims they make directly, and expects proportionate checks on the accuracy of data provided by suppliers before it reaches consumers.
Recent cases have already enforced this, with a German court case exploring whether Apple advertising the Apple Watch as CO₂ neutral is a misleading claim because of the limited duration of the forestry offset leases behind it. A Dutch court also found that KLM had overstated the environmental benefits of sustainable aviation fuel and offsetting in a campaign.
2. What GHG Verification Actually Means
Calculating emissions data is not the same as verifying it. Calculating the data typically requires applying a recognised methodology, such as the GHG Protocol, to activity data across your operations and supply chain. But that calculation only becomes a verified inventory once someone outside your business has checked it.
DoubleHelix provides two related services: verification and validation. Verification checks emissions that have already been reported, whether the figure is accurate, whether the inventory is complete and whether the methodology was applied properly. Validation checks claims about the future: are the assumptions behind a projected reduction reasonable, and is the method capable of delivering what is claimed? Most companies reporting an annual inventory need the first. Anyone making a claim about future performance needs the second.
Furthermore, GHG verification is not yet standard practice. For example, GHG Protocol, one of the most used standards for accounting and reporting on GHG emissions, does not currently require verification of a company’s emissions inventory at all. However, this is changing, as GHG Protocol’s March 2026 draft revisions to its Scope 3 Standard propose that any company that does verify some or all of its Scope 3 emissions must disclose whether that data is “Fully verified,” “Partially verified” or “Not verified.” Scope 3 emissions include all indirect greenhouse gas emissions that occur in a company’s value chain. The proposal has received support, and while it is still draft and subject to change, the direction is clear that an unverified inventory may increasingly need to declare itself as such.
3. How This Connects to the Wider Compliance Picture
GHG verification does not sit apart from the rest of your due diligence obligations. It depends on the same underlying capability of knowing where your products actually come from, not just what your suppliers say. The traceability data that supports an EUDR due diligence statement or a Lacey Act due care programme is the same data that underpins a defensible carbon claim. Businesses treating these as separate workstreams are duplicating effort and leaving gaps in both. Building one defensible compliance programme that can be used across multiple regulations is how strategic businesses can defend their position.
4. Where Supply Chain Data Breaks Down
For businesses sourcing forest-risk commodities, the weakest link in most GHG data sits upstream, in Scope 3 emissions. Land use change, such as the clearing of forests or native ecosystems, is where that weakness is most acute. Primary data on land use change is often scarce, inconsistent or built on different definitions. Traceability varies from supplier to supplier, and where a commodity’s origin is unknown or mixed from different sourcing locations, a company’s emissions calculations may not reflect what actually happened on the ground.
With frameworks such as the Science-Based Targets initiative (SBTi) FLAG setting forest, land and agriculture targets that are increasingly demanding attention alongside regulations like EUDR and the Lacey Act, verification for the underlying data on where a company’s commodities actually came from is becoming critical for businesses.
5. How DoubleHelix Helps With Credible GHG Verification
Credible verification requires independent, third-party assurance against a recognised standard. It means using primary supplier data over industry averages wherever the emissions involved are material, and being transparent about where the data still falls short. It means being able to show your workings if a regulator, journalist or court asks to see them, because it is becoming increasingly likely that someone will ask.
DoubleHelix supports businesses in verifying the accuracy and completeness of their GHG emissions data, in line with international standards. The traceability infrastructure that makes a carbon claim verifiable is the same infrastructure that makes any supply chain claim verifiable. If you cannot trace where your feedstock came from, you cannot credibly claim to know its carbon footprint either. Speak to DoubleHelix about GHG verification and supply chain traceability. We would be glad to assist you.
Read our supply chain traceability guide for more on how traceability underpins every due diligence claim your business makes, or our article, How DNA Testing Is Transforming Timber Supply Chains, for more on how scientific verification confirms what documents cannot.