In the United States, the main federal guidance on green marketing is the Federal Trade Commission’s Green Guides. They include a short section on carbon offsets that applies to anyone who sells offsets or markets products with them. This page explains that section, how the FTC reads broader climate claims, where the review of the guides stands, and a California law that adds disclosure duties. It is part of our claims and rules section.
What the Green Guides are
The Green Guides, at 16 CFR Part 260, set out the FTC’s current views on environmental claims. They help marketers avoid claims that are unfair or deceptive under Section 5 of the FTC ActSource 2. They don’t bind the FTC or the public, but the FTC can take action under the FTC Act if a marketer makes an environmental claim inconsistent with themSource 2.
The guides apply to consumer marketing and also to business-to-business transactions, in labelling, advertising, promotional materials and all other forms of marketingSource 2. The FTC last updated them in 2012, when it added guidance on carbon offset claims among other changesSource 5.
The three rules on carbon offsets
Section 260.5 is short. It sets three rulesSource 1:
- Quantify properly and don’t double sell. Given the complexity of offsets, sellers should use competent and reliable scientific and accounting methods to quantify claimed reductions, and make sure they don’t sell the same reduction more than once.
- Disclose delays. It is deceptive to misrepresent that an offset represents reductions that have already occurred or will occur in the immediate future. Marketers should clearly and prominently disclose if the reductions won’t occur for two years or longer.
- No legally required reductions. It is deceptive to claim that an offset represents a reduction if the reduction, or the activity that caused it, was required by law.
The guides give two examplesSource 1. In the first, an online travel agency sells offsets to “neutralize the carbon emissions from your flight” from projects that won’t cut emissions for two years; that is deceptive, but saying the money funds new projects that begin reducing emissions in two years would not be. In the second, an offset based on landfill methane capture is deceptive because state law already required the capture.
How these rules map to credit quality
Scrolls sideways to show every column.
| FTC rule | What to check before you buy |
|---|---|
| Reliable quantification | An independent standard and methodology, with verified issuance |
| No double selling | Unique serial numbers and a public retirement record |
| Disclose future reductions | Whether the credit is issued after the reduction (ex post) or before it (ex ante) |
| Not required by law | The project’s additionality: would it have happened anyway? |
As of Oct 2026
The left column restates 16 CFR 260.5Source 1; the right column is our own checklist. Our guide to verifying carbon credits shows how to find serial numbers and retirement records.
If you buy offsets rather than sell them, the same rules still shape what you can say. A business that tells customers its product or service is offset is making an environmental marketing claim, so the timing of the reductions and the quality of the credits behind it matter to that claim as much as to the seller’sSource 2Source 1. Ask your provider when the reductions happened and keep the retirement records.
Broader claims: carbon neutral and net zero
The Green Guides don’t define “carbon neutral” or “net zero”. They do warn against broad claims. It is deceptive to misrepresent that a product offers a general environmental benefit, and because unqualified general claims are hard to interpret and likely convey a wide range of meanings, marketers should not make themSource 3. Marketers must make sure every reasonable interpretation of a claim is truthful and supported by a reasonable basis before making itSource 4.
Claims: what US guidance points to
- Risky: “This product is carbon neutral” with no explanation of what was measured, cut and offset.
- Risky: offsets sold as cancelling emissions now when the projects deliver reductions years laterSource 1.
- Better: “We retired [number] tonnes of [standard] credits from [project], issued for reductions in [year]. See the registry record.”
The Green Guides review
The FTC reviews the Green Guides on a ten-year (decennial) scheduleSource 6. On 20 December 2022 it published a request for public comment on whether to retain, modify or rescind the Green GuidesSource 6. The notice asked whether the carbon offset section should be revised, and whether there was consumer research on how people understand claims such as “net zero”, “carbon neutral”, “low carbon” and “carbon negative”Source 6. The FTC later extended the comment deadline to 24 April 2023Source 7.
As of October 2026, no revised guides have been published; the FTC’s Green Guides page still presents the 2012 versionSource 5. Until that changes, 16 CFR 260.5 remains the federal reference point.
California: the Voluntary Carbon Market Disclosures Act
States can add their own rules. California’s AB 1305 added section 44475.2 to the Health and Safety Code, effective 1 January 2024Source 8. An entity that claims net zero emissions, claims that it or a product is “carbon neutral”, or implies it doesn’t add net greenhouse gases or has made significant reductions, must disclose on its website how the claims were determined to be accurate or achieved, how progress is measured, and whether there is independent third-party verificationSource 8. The section doesn’t apply to entities that neither operate in California nor make claims thereSource 8.
For the same questions in other markets, read our pages on UK rules and carbon neutral claims. If you are buying credits in the US, see our United States guide.