TLDR
The ACCC released a 24-page guide on 20 October 2026 telling brands that purchased carbon credits cannot be presented as actual emissions reductions in consumer advertising. It asks brands making 'carbon neutral' or 'net zero' claims to disclose credit use and use science-based accounting, and says it may take targeted enforcement action.
KEY TAKEAWAYS
What the guide asks for
The ACCC published "Making emissions claims to consumers - a guide for business" on 20 October, applying its 2023 environmental claims guidance to the way brands talk about their carbon footprint.[1] It asks businesses to use credible, science-based accounting, to disclose any purchased credits, and to think about what an average consumer will take a claim to mean.[2] "Consumers should be able to trust the emissions-related claims that businesses make," ACCC deputy chair Mick Keogh said.[1]
On credits, the guide is blunt: if marketing gives the impression that buying credits and emitting cancel each other out, the business needs a reasonable basis for that claim.[2] According to PPC Land's reading of the 24-page document, avoided-emissions credits generally can't back a "zero impact" claim, disclaimers rarely fix a prominent headline, and forest or smiling-planet imagery can make a business look greener than it is on its own.[3]
What changes for marketers and agencies
The format matters as much as the claim. Billboards and TV should carry simple, specific facts, with the nuance moved to a web page or QR code, and future targets such as "net zero by 2050" are usually unsuitable for short-form advertising, PPC Land reported.[3] That puts the creative team, not just the sustainability lead, on the hook for what goes on a 15-second spot or a six-sheet.
"We strongly encourage businesses to review their consumer facing emissions claims in light of our guidance," Keogh said.[1] The ACCC says large companies in aviation, energy, logistics and telecommunications have already changed their claims, some dropping vague "carbon neutral" language and distant targets, and that it may take targeted enforcement action against problem conduct that continues.[2]
The enforcement backdrop
The guide itself has no legal force; whether a claim breaches the Australian Consumer Law is for the courts.[3] But the ACCC's release points to what that looks like: the Federal Court ordered Clorox Australia to pay $8.25 million in penalties over misleading "ocean plastic" claims on some GLAD products, and the ACCC has started Federal Court proceedings against Australian Gas Networks over its renewable gas campaign and against the maker of Banana Boat and Hawaiian Tropic over "reef friendly" sunscreen claims.[1]
SOURCES & CITATIONS
FREQUENTLY ASKED QUESTIONS
Can a brand still use 'carbon neutral' in advertising?
What penalty does a brand face for a misleading emissions claim?
Does a disclaimer fix a misleading headline claim?
James Dore is founder and editor of Prompt the Market and Strategy Director at Bushnote, a Sydney strategy, SEO and AI search agency. He has a background in strategy, media and financial services, and led consumer product marketing at MONEYME. He writes on AI search, answer engines, technology policy and media economics.
