Recital 12 of the EU's 2024 greenwashing directive lists "climate compensated" and "climate neutral" among the claims banned when they rest on offsets.
A few lines later, the same recital says companies can still advertise "their investments in environmental initiatives, including carbon credit projects," as long as they do it without misleading anyone. The money and the credits can be exactly the same. What the directive cares about is how you describe them.
Travel-benefit vendors' climate wording splits the same way. Some phrases describe your trip: it's carbon neutral, it's offset, it runs on renewable power. Others describe what the vendor pays for: it funds solar, it plants trees. The first kind needs your trip's emissions measured and matched. The second needs the money traced. Most weak claims are a phrase of the first kind held up by evidence of the second.
How to use this checklist on a vendor call
Ask the vendor for the exact sentences your employees will see: the booking page, the welcome email, the impact dashboard, the annual summary. Then run each one through the table.
The last column names the published rules and standards that speak to each phrase. Whether any of them applies to you or your vendor is a question for your own counsel.
Three related guides cover the ground around this one. The six documents worth getting in writing are in how employers evaluate transaction-funded climate-impact benefits. Whether a vendor's number can go into your own disclosure is in how to evaluate a travel provider's climate-impact report. The same wording seen from the traveler's side, at the point of booking, is in how to spot greenwashing when you book travel.
The climate-impact claim checklist
| The phrase | What has to be true | Ask for | Published text that addresses it |
|---|---|---|---|
| "Carbon neutral travel" | Under ISO 14068: emissions measured, real reductions made, and only the remainder covered by retired credits. EU point 4c bans the claim when it rests on offsetting | The footprint boundary, what was reduced first, and the retired credits with serial numbers | ISO 14068; EU Directive 2024/825, Annex I point 4c; FTC 16 CFR 260.5 |
| "Offsets your trip" | Each ton is quantified, sold once and wasn't required by law, and any reduction two or more years away is disclosed | Registry, serial numbers, the name the credits are retired under, and when the reductions occur | FTC 16 CFR 260.5; EU 2024/825, point 4c |
| "Plants a tree per booking" | A tree goes in the ground for each booking, and any carbon claimed from it is counted once | Planting partner, location, survival monitoring, and whether carbon credits are issued from the trees | FTC 16 CFR 260.5 if presented as an offset; EU 2024/825, recital 12 |
| "Renewable-powered" | The electricity behind the service is renewable, or matched with certificates the vendor holds and retires | Which facilities, what percentage, and which certificates, retired by whom | FTC 16 CFR 260.15; GHG Protocol Scope 2 Guidance; EU 2024/825, point 4b |
| "Funds solar" | Money reached named solar projects, and the vendor can say what kind of money and how much is built | Project list, built versus pipeline, grant, loan or equity, and full project size versus the vendor's share | FTC 16 CFR 260.4; EU 2024/825, recital 12; ICMA impact reporting handbook |
| "X tons avoided" | A stated method turned measured or expected generation into tons, for operating capacity only | MWh, the grid factor with its source and year, annual or lifetime, and whole project or pro-rated share | ICMA impact reporting handbook; GHG Protocol Scope 3 Standard, section 9.5 |
| "Net zero" | There's a dated target with a plan, interim milestones and an independent party checking progress | Target year and scopes, the implementation plan, and the latest verification report | EU 2024/825, Article 6(2)(d) |
"Carbon neutral travel" and "offsets your trip"
Carbon neutral has the most rules behind it. The standard is ISO 14068 (renumbered from ISO 14068-1 in September 2026, same content), and BSI's summary says claims "can only be made after the development of long-term planning, with real GHG reductions in place," and limits offsetting to "residual emissions using high quality carbon credits."
So the first question for a carbon-neutral travel benefit is what was reduced before anything was offset. If the answer is nothing, the claim rests on credits alone.
The EU directive's point 4c goes further. It bans claiming, "based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions." EU countries apply it from September 27, 2026.
"Offsets your trip" makes a narrower promise, and the FTC's offsets section gives it a template. Its example of an online travel agency finds "neutralize the carbon emissions from your flight" deceptive when the projects won't cut emissions for two years.
The wording the FTC accepts is "Offset the carbon emissions from your flight by funding new projects that will begin reducing emissions in two years."
A version that holds up: "We retired [n] tons of verified credits from [project] on [registry], serials [range], to cover the flights booked through us in [period]."
"Plants a tree per booking"
"We plant a tree for every booking" is a count, and a planting partner's records should match your booking volume. Once it turns into "your stay's emissions are absorbed," it's an offset claim, and the FTC's timing rule asks for clear disclosure when reductions "will not occur for two years or longer."
Ask whether anyone issues carbon credits from those trees. If a planting partner sells them to a third party, that buyer holds the carbon claim, and the vendor can't also hand it to you.
Wording a vendor can stand behind: "We pay [partner] to plant one tree in [region] for each booking. We don't count the trees against your trip's emissions."
"Renewable-powered"
The FTC's renewable energy section says marketers shouldn't make an unqualified renewable claim if fossil electricity powers "any part of the advertised service," unless they've matched that use with renewable energy certificates. Who holds those certificates decides the claim, and the test for who holds the certificate covers it in detail.
Ask what exactly is powered. A booking platform can power its offices and servers. It doesn't power the hotel or the flight, and "renewable-powered travel" reads as if it did. The EU directive's point 4b bans a claim about "the entire product" that "concerns only a certain aspect" of it.
A version that holds up: "Our offices and servers run on electricity matched with renewable energy certificates we retire. The trips you book don't."
"Funds solar"
This phrase has the most room, because it describes what the vendor pays for. The same EU recital that explains the offset ban also allows companies to advertise their investments in environmental initiatives. What makes it hold is detail: which projects, how much is built and how much is in development, and whether the money is a grant, a loan or an equity stake.
Scale matters too. The FTC's general-claims section says marketers "should not imply that any specific benefit is significant if it is, in fact, negligible." And the ICMA impact reporting handbook, written for green bond issuers, asks reports to give the "total project size and/or the issuer's share of total financing." A vendor quoting megawatts should say which of the two it means.
The phrase can't stretch into "renewable-powered" either. Paying for a solar project gives the vendor no claim to using its electricity. The six questions for testing a solar claim itself are in how employers can assess community-solar impact claims.
Wording a vendor can stand behind: "Part of our profit funds solar projects. [n] MW of the projects we've helped fund are operating and [n] MW are in development. These are full project sizes, and our money is one part of each."
"X tons avoided"
The ICMA handbook's core indicator for renewable energy projects is "annual GHG emissions reduced/avoided in tonnes of CO2 equivalent," and it says "the GHG accounting methodology and assumptions should be referenced." It also warns that portfolios are hard to compare because assumptions such as grid factors and calculation methods "also vary significantly."
Ask to see the math: the megawatt-hours, the grid factor with its source and year, whether it's one year or a 30-year lifetime, and whether it covers whole projects or the vendor's pro-rated share. The questions behind those inputs are in the same community-solar guide.
Then keep the number away from your inventory. The GHG Protocol's Scope 3 Standard, section 9.5, says avoided emissions "must be reported separately from a company's scope 1, scope 2, and scope 3 emissions, rather than included or deducted from the scope 3 inventory."
A version that holds up: "Projects we've helped fund avoid an estimated [n] tons of CO2 a year, using [grid factor, source, year]. The figure covers whole projects and is separate from your travel emissions."
"Net zero"
Net zero is usually a company target dressed as a product feature. Ask whose net zero it is: the vendor's own operations, or the trips it sells you. A target decades out says little about a trip booked this month.
The EU directive treats a claim about "future environmental performance" as misleading without "a detailed and realistic implementation plan that includes measurable and time-bound targets," "regularly verified by an independent third party expert." That's a good list of documents to ask for, wherever the vendor sells.
A version that holds up: "We've set a net zero target for scopes 1, 2 and 3 by [year], with an interim target for [year]. [Verifier] checks progress each year, and the latest report is public."
Running the checklist on Dyme's own phrases
Dyme uses two of these phrases. "Funds solar": we use profit from bookings to fund new solar projects. Our money can go into any layer of a project, from a loan to an ownership stake, and it's paid back and goes into more solar. Our How Dyme works page lists the project types, led by agrivoltaic solar in India.
Projects we've helped fund total 5.5 MW built and operating, with 20 MW more in the pipeline. The 5.5 MW is the full size of those projects, not our share, and we don't publish what share of profit goes to solar.
"Tons avoided": our 5,910 tons a year comes from 7,807 MWh multiplied by 0.757 tCO2/MWh, the 2023-24 combined margin from version 20.0 of India's Central Electricity Authority database. It covers the whole projects, and it hasn't been independently audited.
The "about 271,000 mature trees" on our results page is the annual tonnage restated as trees. We don't buy renewable energy certificates or offsets, so we don't call your trip carbon neutral or renewable-powered. The full math is in how we calculate Dyme's renewable energy impact.
FAQ: climate-impact claims from travel-benefit vendors
What should a travel-benefit vendor be able to show for a climate-impact claim?＋
Two different things, depending on whether the claim is about your trip or about the vendor's spending. A claim about your trip, such as carbon neutral or offset, needs the trip's emissions measured and retired credits with serial numbers. A claim about what the vendor funds, such as solar, needs the projects named, how much is built, and what kind of money went in. Ask for the exact sentences your employees will see and test each one separately.
Can a travel benefit make our employees' trips carbon neutral?＋
A vendor would need the trip's emissions measured and retired credits to cover them, and ISO 14068 expects real reductions before any offsetting. The EU's Directive 2024/825 bans claiming, "based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions." EU countries apply it from September 27, 2026. Whether either applies to your program is a question for your counsel.
Is "funds solar" a weaker claim than "carbon neutral"?＋
It's narrower, which usually makes it easier to back up. It describes where the vendor's money goes, so it needs the money traced to named projects. It doesn't say anything about your trip's emissions, and it doesn't mean the vendor uses the solar power.
Can we subtract a vendor's tons avoided from our travel emissions?＋
No. The GHG Protocol's Scope 3 Standard, section 9.5, says avoided emissions must be reported separately from scope 1, 2 and 3 emissions, "rather than included or deducted from the scope 3 inventory."
Does a vendor buying renewable energy certificates make our travel renewable-powered?＋
Certificates can back a claim about the electricity the vendor uses, such as its offices and servers. They don't power the hotel or the flight. The FTC's renewable energy section (16 CFR 260.15) and the EU directive's point 4b, which bans claims about a whole product when only one part qualifies, both cover this.
