Carbon neutrality · updated 28 September 2026
PAS 2060 and ISO 14068: carbon neutral certification after the switch
PAS 2060 was withdrawn by BSI at the end of 2025. Nobody can be verified against it today.
Its replacement, ISO 14068-1:2023, was withdrawn by ISO on 11 September 2026 and is being replaced by ISO 14068:2026. And in the UK, a carbon neutral claim is only as safe as the evidence and qualifications behind it.
Can we say carbon neutral?
It is against UK law to describe a product as carbon neutral.
Not quite. The statement is false.
On our reading of the Act, no. Schedule 20 to the DMCC Act 2024, the list of practices banned outright, says nothing about carbon or offsetting. A carbon neutral claim becomes unlawful when it misleads, which turns on the wording and the evidence behind it. 363
An ad can say “carbon neutral” as long as the offsetting detail is on our website.
Not quite. The statement is false.
Probably not. CAP guidance says to avoid unqualified carbon neutral claims, and in its BrewDog ruling of 20 December 2023 the ASA found a website link was not enough: the basis had to be in the ad itself. 364
The CMA Green Claims Code stopped applying when the law it cites was repealed.
Not quite. The statement is false.
The Code, published on 20 September 2021 and never updated, still cites the 2008 regulations the DMCC Act replaced. But the CMA has not withdrawn it, built on it in January 2026, and CAP tells marketers to take account of it, so it is best read as the CMA’s current view. 364285
ISO 14068-1:2023 is the current carbon neutrality standard.
Not quite. The statement is false.
ISO withdrew it on 11 September 2026, and its record names ISO 14068:2026 as the revision. The new edition’s own record still showed it under publication on 28 September, so check which edition your verifier is working to. 693
A first ISO 14068 claim can rest entirely on offsets.
Not quite. The statement is false.
UKAS’s migration bulletin says it cannot, and the standard puts reductions and removal enhancements in the value chain ahead of offsetting. Expect to evidence an actual reduction in every cycle, the first included. 693
The FCA anti-greenwashing rule covers a bank’s carbon neutral claim about itself.
An offset-based “carbon neutral” product claim is treated differently in the EU and the UK.
Not quite. The statement is true.
Directive (EU) 2024/825 required member states to apply a ban on offset-based product neutrality claims from 27 September 2026. The UK has no equivalent rule, so the same claim needs separate advice for each market. 285
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What PAS 2060 was
PAS 2060 was BSI's Specification for the demonstration of carbon neutrality. The 2014 edition, PAS 2060:2014, was published on 30 April 2014. It set out what an entity had to do to claim that a product, organisation, event or building was carbon neutral: quantify the footprint, reduce it, offset the rest and publish a declaration.
For years it was the reference point for UK carbon neutral claims. It sat on top of an emissions inventory, usually built on the scope 1, 2 and 3 split, and was verified by a third party.
It no longer exists as a live credential. The phrase “PAS 2060 certified” still appears on many UK websites and in tender documents, and some providers' pages still advertise PAS 2060 verification. Treat any present-tense PAS 2060 claim as out of date.
When PAS 2060 was withdrawn
Three dates are routinely mixed up. BSI's product record for BS ISO 14068-1:2023set the rule: “There will be a period of 24 months from the date of publication of ISO 14068-1:2023 before the PAS 2060:2014 document will be withdrawn.” The verification scheme and accreditation ran to their own deadlines.
The accreditation side is in the UKAS technical bulletin on migrating from PAS 2060, which set 31 December 2025 as the migration deadline, with PAS 2060 “to be removed from current schedule”.
The safe wording is “withdrawn by BSI at the end of 2025”. It is true against all three dates. Do not write that old opinions were invalidated: they were not.
ISO 14068: what replaced PAS 2060
ISO 14068-1:2023, Climate change management — Transition to net zero — Part 1: Carbon neutrality, was published in November 2023. BSI's carbon neutrality verification page describes it as built from the principles of PAS 2060.
It is no longer current. The ISO catalogue record for ISO 14068-1:2023 shows the standard withdrawn on 11 September 2026 (stage 95.99) and revised by ISO 14068:2026, Climate change management — Carbon neutrality. The two ISO records do not yet agree: the record for the new edition still showed it as under publication on 28 September 2026, with a publication date of September 2026 and no day given. We say the 2023 edition was withdrawn and is being replaced, and we do not print a publication day.
How ISO describes the 2026 revision
The foreword to ISO 14068:2026 says the first edition 'cancels and replaces ISO 14068-1:2023, of which it constitutes a minor revision'.
The listed changes are that the title has been updated and the part number has been removed.
On ISO's own account, then, the changes are the title and the part number, not the requirements. The designation still matters for accuracy: cite the edition year, and expect verifiers and their documents to move to the new number. The ISO 14068:2026 foreword and contents are publicly available as a sample.
What ISO 14068 requires
The standard applies to organisations and to products, including buildings and events. It does not apply to territories. Its core is a hierarchy: reduce emissions and enhance removals within the value chain first, then offset what remains.
| Clause | What it covers |
|---|---|
| 6 | A commitment to carbon neutrality |
| 7 | Selecting the subject and setting its boundary |
| 8 | Quantifying GHG emissions and removals |
| 9 | A carbon neutrality management plan, with ambition, evaluation and revision |
| 10 | GHG emission reductions and removal enhancements |
| 11 | Offsetting the remaining footprint, with criteria for carbon credits and crediting programmes |
| 12 | A carbon neutrality report |
| 13 | Carbon neutrality claims |
UKAS summarised what changed from PAS 2060. The list matters because it is exactly where old PAS 2060 habits fail.
| Area | Under ISO 14068 (per UKAS) |
|---|---|
| First claim | Cannot be based entirely on offsets |
| Reductions | Actual evidence of a reduction is required for every reporting cycle, including the first; a stated intention is not enough |
| Quantification | ISO 14064-1 methodology for organisations; ISO 14067 for products |
| Verification | ISO 14064-3 is normative, so its content forms part of the requirements |
| Hierarchy | Reduce and remove before offsetting, set out more explicitly than in PAS 2060 |
The quantification layer is ISO 14064-1. Its ISO catalogue recordshows the 2018 edition as current but flagged “to be revised”. Our guide to GHG verification standards covers ISO 14064-3 and ISO 14065.
Carbon neutral claims and UK law
ISO 14068 is a voluntary standard. It does not make a claim lawful. What governs a UK carbon neutral claim sits in three tiers: law, regulator guidance and advertising self-regulation.
| Tier | Instrument | What it means for a carbon neutral claim |
|---|---|---|
| Law | DMCC Act 2024, Part 4 Chapter 1 | Misleading actions (s.226) and omissions (s.227) are unfair commercial practices, prohibited by s.225 |
| Guidance | CMA Green Claims Code and supply-chain guidance | Claims must be truthful, clear, complete, fair, consider the full life cycle and be substantiated |
| Self-regulation | CAP Code section 11 and CAP guidance | The basis of the claim must be clear; unqualified carbon neutral claims should be avoided |
| Financial services | FCA anti-greenwashing rule, ESG 4.3.1R | Sustainability references about products and services must be fair, clear and not misleading |
The consumer protection provisions in Part 4 of the Digital Markets, Competition and Consumers Act 2024 apply to practices from 6 April 2025. Its Schedule 20 blacklist contains nothing about carbon or offsetting, so no offset-based claim is banned outright. A claim is unlawful when it misleads.
The bite is enforcement. The CMA can now decide for itself that consumer law has been broken, and its summary of those direct enforcement powerssays a penalty “can be up to 10% of your business' global turnover or £300,000 (whichever is greater)”.
The CMA's Green Claims Code was published on 20 September 2021 and has not been updated since. It still cites the repealed 2008 regulations, but the CMA says its guidance continues to apply in substance. Its January 2026 note, Making green claims across the supply chain, adds that a business repeating a supplier's claim is responsible for it too.
"CAP Guidance sets out that marketers should avoid using unqualified 'carbon neutral' or 'net zero' claims."CAP AdviceOnline, 17 June 2026
That line comes from CAP's advice on carbon offsetting and carbon neutral claims. It builds on CAP Code rule 11.1: “The basis of environmental claims must be clear. Unqualified claims could mislead if they omit material information.” The ASA upheld complaints against Charles Tyrwhitt's “Carbon Neutral business” and BrewDog's “carbon negative” claims on 20 December 2023. In BrewDog's case a link to offsetting detail on its website was not enough; the basis had to be in the ad itself.
Financial firms carry one more layer. The FCA's anti-greenwashing rule, ESG 4.3.1R, has applied to all authorised firms since 31 May 2024 for references to products and services. The Handbook section it sits in, ESG 4.3, now shows a last-updated date of 25 September 2026, because ESG 4.3.2R and ESG 4.3.3G changed; the rule itself still carries its 28 February 2025 text. The FCA's guidance, FG24/3, reminds firms that claims about themselves are caught by the CMA and ASA guidance and the FCA Principles instead. Our anti-greenwashing rule guide covers the detail.
The EU has gone further. Directive (EU) 2024/825 blacklists any claim, based on offsetting, that a product has a neutral, reduced or positive greenhouse gas impact. Member States apply it from 27 September 2026. The UK has no equivalent rule.
What a defensible carbon neutral claim contains
A carbon neutral claim that is likely to survive a complaint answers, in the claim itself, the questions a reader would ask. CAP's advice lists them: set out the basis, say whether the claim rests on offsetting or on reducing emissions and to what extent, and give information about any offsetting scheme used. ISO 14068 adds the structure behind it: a defined subject, a boundary, a period, a management plan and a report.
Weak and stronger wording
| Wording | Why it matters |
|---|---|
| “We are a carbon neutral business.” | Unqualified. The ASA upheld a complaint about this form of words against Charles Tyrwhitt on 20 December 2023 |
| “Carbon neutral. Find out more on our website.” | The basis sits outside the claim, which is what the BrewDog ruling found insufficient |
| “Our UK operations were carbon neutral for calendar 2025, verified to ISO 14068 by [verifier]. We cut emissions by [x]% on 2024 and offset the remaining [y] tCO2e through [scheme].” | Subject, period, standard, verifier, the reduction and the offset share, all in the claim |
ISO 14068, SBTi net zero and ISO 14064
Carbon neutral and net zero are different claims, and the ASA has found consumers use them interchangeably. The table sets out how the three frameworks relate.
| ISO 14068 | SBTi Corporate Net-Zero Standard | ISO 14064-1 | |
|---|---|---|---|
| What it is | A standard for demonstrating carbon neutrality | A framework for validating science-based targets | A standard for quantifying and reporting an organisation’s GHG inventory |
| Role of credits | Offset the footprint left after reductions, against set criteria | A complement, not a substitute, for reducing emissions | None; it measures emissions and removals |
| Output | A verified carbon neutrality claim for a subject and period | Validated near-term and net-zero targets | A GHG statement, verifiable under ISO 14064-3 |
| Current version | ISO 14068:2026 (the 2023 edition withdrawn 11 Sep 2026) | V1.3.1 in use; V2.0 published 11 June 2026 | ISO 14064-1:2018, flagged for revision |
The two are not alternatives. A company can hold science-based targets and make a verified carbon neutral claim, provided the claim does not suggest the targets have been met through offsets. The SBTi's page on Version 2.0 sets out the new implementation hierarchy. Companies submitting targets in 2026 should still use V1.3.1, which remains open until 31 January 2028; our guide to Corporate Net-Zero Standard V2 explains the transition.
Moving on from a PAS 2060 opinion
There is no grace period to wait out. BSI stopped delivering the PAS 2060 scheme on 1 January 2025 and the last opinions closed on 31 December 2025, so a carbon neutral claim for any later period needs ISO 14068. An old opinion is not wasted: the footprint, reduction evidence and offset records behind it are most of what an ISO 14068 verifier will ask for. These are the steps, in order.
| Step | What to do | Why |
|---|---|---|
| 1. Find every present-tense claim | Website, packaging, tender answers, sustainability report, email footers | A present-tense “PAS 2060 certified” is the commonest dead credential in UK copy |
| 2. Re-describe the old opinion | Name the period it covered and the standard, in the past tense | An opinion stays valid for its period; it was never invalidated |
| 3. Gap-analyse against ISO 14068 | Check the UKAS list: no offset-only first claim, reduction evidence every cycle, ISO 14064-1 or ISO 14067 quantification, ISO 14064-3 verification | These are where PAS 2060 habits fail |
| 4. Write the management plan | Set the commitment, ambition and review points Clauses 6 and 9 ask for | A claim with no plan behind it has nothing to verify against |
| 5. Choose a verifier and ask about the edition | Use a verifier accredited for the scheme; ask whether they will verify to ISO 14068:2026 and from when | The 2023 edition was withdrawn on 11 September 2026 |
| 6. Rewrite the claim | Put subject, period, standard, reduction and offset share in the claim itself | CAP guidance and the ASA rulings |
| 7. Split the markets | Drop offset-based product neutrality claims in EU marketing; keep UK claims qualified | Directive (EU) 2024/825 applies from 27 September 2026; the UK has no equivalent |
A group that also reports under SECR or plans for UK SRS S2 should build the ISO 14068 footprint from the same inventory, so one set of numbers supports every statement. Our guide to the Carbon Trust Standard covers a different label, with its own rules on what a holder may say publicly.
If you hold or want a carbon neutral claim
| Situation | What to do |
|---|---|
| You still say "PAS 2060 certified" | Remove the present-tense claim. Describe any past opinion by its period, or move to ISO 14068 |
| You plan an ISO 14068 claim | Show real reductions first; a first claim cannot rest on offsets alone |
| You advertise to consumers | Put the basis in the claim itself: offset share, scheme, subject and period |
| You sell into the EU | Do not make offset-based product neutrality claims there from 27 September 2026 |
| You are an FCA-authorised firm | Check product and service claims against ESG 4.3.1R |
| You set net zero targets | Keep credits separate from reductions in both the targets and the messaging |
Other labels sit alongside ISO 14068 and do different jobs. See our guide to Planet Mark before choosing one, and check what each will let you say publicly.
What this means for your organisation
The same two words carry different risks depending on who says them and to whom. Pick the description that fits; each tab says what applies, what to do next and by when.
Carbon neutral claims: where things stand
The timeline marks what has passed and what comes next as of the day you read it. ISO gives the new edition's publication only as September 2026, so it is marked by the withdrawal of the old one.
Carbon neutrality terms explained
- Carbon neutralityISO 14068
- A state in which a subject’s carbon footprint for a period has been reduced and the remainder offset.
- Carbon footprintISO 14068
- The GHG emissions and removals of the subject, quantified for the period of the claim.
- OffsettingClause 11
- Counterbalancing the remaining footprint with carbon credits that meet the standard’s criteria.
- Carbon creditClause 11
- A tradable unit representing a GHG reduction or removal, issued under a crediting programme.
- Removal enhancementClause 10
- Action that increases GHG removals within the value chain; ranks with reductions, ahead of offsetting.
- Carbon neutrality management planClause 9
- The plan setting out how carbon neutrality will be achieved and kept, with ambition, evaluation and revision.
- Verification opinionPAS 2060
- A verifier’s statement about a claim for a stated period. Valid for that period only.
- Unqualified claimCAP 11.1
- A claim stated without its basis. The ASA treats an unqualified carbon neutral claim as misleading.
- Misleading omissionDMCC s.227
- Leaving out information the average consumer needs, so that a claim misleads.
- Schedule 20DMCC Act
- The list of practices banned outright. It contains nothing about carbon or offsetting.
- Anti-greenwashing ruleESG 4.3.1R
- The FCA rule that product and service sustainability references be fair, clear and not misleading.
- Net zeroSBTi
- A target built on deep reductions in the physical inventory; credits complement, not substitute.
PAS 2060 and ISO 14068 questions answered
Is PAS 2060 still valid?
No new PAS 2060 verification is available.
BSI stopped delivering the PAS 2060 scheme from 1 January 2025, the last verification opinions were issued by 31 December 2025, and the document was withdrawn by BSI at the end of 2025.
An opinion issued for a past period remains valid for that period, but it is not a current credential.
What replaced PAS 2060?
ISO 14068-1:2023, the international carbon neutrality standard, replaced PAS 2060.
ISO withdrew that standard on 11 September 2026 and is replacing it with ISO 14068:2026, which ISO describes as a minor revision that updates the title and removes the part number.
ISO’s own record for the new edition still showed it as under publication on 28 September 2026.
What is ISO 14068?
ISO 14068 sets principles, requirements and guidance for achieving and demonstrating carbon neutrality through the quantification, reduction and offsetting of a carbon footprint.
It applies to organisations and products.
It sets a hierarchy in which emission reductions and removal enhancements within the value chain come before offsetting, and it includes requirements for carbon neutrality commitments and claims.
Can you get ISO 14068 certified?
ISO does not certify anyone.
An organisation or product is verified against ISO 14068 by a third party, such as a validation and verification body accredited by UKAS.
BSI, for example, offers a Kitemark for Carbon Neutrality for products verified to the standard.
What should we do with an old PAS 2060 opinion?
Keep it, and describe it by the period it covered.
An opinion issued for a past period remains valid for that period, but it cannot support a present-tense claim.
Remove any “PAS 2060 certified” wording, check your data against the ISO 14068 requirements, and ask a verifier which edition of ISO 14068 they will verify to.
Is it legal to say carbon neutral in the UK?
Yes, if the claim is true, substantiated and not misleading.
No UK law bans offset-based carbon neutral claims, and the blacklist in Schedule 20 to the Digital Markets, Competition and Consumers Act 2024 says nothing about carbon.
But a misleading claim breaches the Act, the CMA can now fine a business directly, and the ASA treats an unqualified carbon neutral claim as misleading.
Is carbon neutral the same as net zero?
No.
Under ISO 14068, carbon neutral means the remaining footprint for a period has been counterbalanced by offsetting after reductions.
A science-based net zero target, such as one validated by the SBTi, is built on deep reductions in the physical inventory, and the SBTi treats carbon credits as a complement to reductions, not a substitute for them.
Does the EU ban carbon neutral claims?
From 27 September 2026, Directive (EU) 2024/825 adds to the EU blacklist any claim, based on offsetting, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.
The UK has no equivalent rule, so a UK business marketing products into the EU needs to treat the two markets differently.
Before you rely on it
A checker gives a provisional position, not a verdict
Scope for a carbon neutral claim turns on facts a form cannot see: how the group is structured, which figures count, and what has changed since the last period. Put your own figures to the member agent, which answers from the same sourced corpus as this page and says where it is unsure, or book a call.
Primary sources for this page
Related guides & references
GHG verification standards
ISO 14064-3, ISO 14065 and how a GHG statement is verified.
The FCA anti-greenwashing rule
What ESG 4.3.1R covers, and the four things it does not.
SBTi Corporate Net-Zero Standard V2
What changed in V2.0, and why V1.3.1 still governs today.
Carbon offset consultants
What an offsetting adviser does, and what to ask before you buy credits.