Carbon Neutral, Net Zero or 100% Renewable? What the ACCC Now Expects You to Prove

On 20 October 2026 the ACCC published Making emissions claims to consumers, its first guide written specifically for greenhouse gas claims. Three months earlier, the federal government proposed closing Climate Active, the scheme behind most of the “carbon neutral” logos on Australian websites and packaging. Put together, the two changes mean a claim like “carbon neutral” or “100% renewable” now has to stand on its own evidence.

Those two claims are often used as if they mean the same thing. They do not, and the evidence each one needs is different. This article sets out what each claim means, what the ACCC now expects behind it, and what I look for when I audit an environmental management system that makes one.

Short answer

• Carbon neutral means net emissions inside a stated boundary are zero now, usually with carbon credits. 100% renewable usually means only the electricity is matched by renewable generation. Net zero is normally a future target built on deep cuts.
• The ACCC guide sets six tests: sound accounting, specific wording, transparency about credits, no double counting, claiming only your own action, and a reasonable basis for future targets.
• Climate Active certification is proposed to end on 30 June 2027 after a transition period, and its carbon neutral standards and trade marks would be discontinued.
• What to do: list every emissions claim you make, check each one against the guide, and make sure your environmental management system can produce the evidence on request.

Carbon neutral, net zero and 100% renewable are three different claims

The gap between the first and third rows is where many businesses get caught. An office running on GreenPower can fairly say its electricity is 100% renewable. It cannot say the business is carbon neutral on that basis, because its fleet, gas, flights and suppliers still produce emissions. Going the other way, a carbon neutral business may still be buying electricity from the grid and covering it with credits.

What the ACCC’s October 2026 guide expects

The guide builds on the ACCC’s 2023 guidance on environmental claims and applies to marketing, packaging, websites and point-of-sale material. Its test is the overall impression a claim leaves with an ordinary consumer. It is organised around six prompts:

1. Accounting: claims rest on a complete, reputable accounting method that covers all significant emission sources. Quoting scope 1 and 2 figures while leaving out a large scope 3 footprint can mislead.
2. Specificity: absolute terms such as “carbon neutral”, “net zero” and “clean” are risky in short-form marketing. Say what is being compared and over what period.
3. Credits: be open about reliance on carbon credits, including the project, scheme and registry. The guide treats “offset” on its own as jargon that can mislead.
4. Double counting: each credit or benefit is claimed once, and credits are retired. Claiming on-site solar as an emissions cut while selling the certificates it generates is double counting.
5. Your own action: do not claim reductions that come from the grid getting cleaner, or from changes the law already required.
6. Future claims: a target needs reasonable grounds, stated assumptions and a documented basis. “Net zero by 2050” with no plan behind it is the guide’s own example of a problem.

ACCC Deputy Chair Mick Keogh said “consumers should be able to trust the emissions-related claims that businesses make”. Greenwashing remains an enforcement priority. The ACCC has secured $8.25 million in penalties against Clorox Australia over “ocean plastic” claims, and has proceedings under way against Australian Gas Networks over its renewable gas campaign and against the maker of Banana Boat over “reef friendly” claims. It has also said it has seen large companies move away from vague carbon neutral claims, and will consider targeted action against businesses that do not.

Where “100% renewable” claims go wrong

Renewable claims look simpler than carbon neutral claims, so they get less scrutiny inside the business. The guide singles out two problems:

• Borrowing the grid’s progress. A business that has bought no renewable electricity and describes its operations as “35% renewable” because that is the grid mix is likely to mislead. That figure is the grid’s achievement, not the business’s.
• Selling the certificates and keeping the claim. On-site solar creates certificates. If they are sold to someone else, the renewable attribute goes with them. The business can say it hosts solar panels, but it cannot also count that electricity as renewable in its own claims.

The safe version of the claim is narrow and specific: “our electricity is matched by GreenPower and surrendered certificates” says what was done. “We run on 100% renewable energy” invites the reader to assume the fleet, the gas and the suppliers are covered too.

Climate Active is ending. What replaces the logo?

The Department of Climate Change, Energy, the Environment and Water has proposed ending Climate Active certification on 30 June 2027, after a transition period. The Climate Active brand, trade marks and consultant register would be discontinued, along with the current carbon neutral standards. Consultation closed on 18 September 2026, and the final decision has not yet been announced. The department’s reasons include mandatory climate reporting, maturing international frameworks, and a shift in expectations toward direct emissions cuts.

For a business that relies on the logo, the practical effect is that the claim loses its third-party backing. The obligation not to mislead does not go anywhere. The reference points that remain are international standards: ISO 14064-1 for an organisation’s greenhouse gas inventory, and ISO 14068-1:2023 for carbon neutrality claims, which expects reductions to come first and credits to be used only for what is left. Many organisations will also find their large customers asking for emissions data as those customers report under AASB S2, which our article on scope 3 supplier questionnaires covers.

One more consistency check is worth making. If your business, or a parent company, reports emissions under the mandatory climate reporting regime, the numbers in that report and the claims in your marketing should tell the same story. The ACCC guide does not cover mandatory reports, but a gap between the two is an easy thing for a regulator, a journalist or a competitor to find.

What an auditor looks for in ISO 14001 terms

An environmental claim is an output of the environmental management system, so ISO 14001 already asks the right questions. When I audit a system that makes emissions claims, I look at:

• Clause 6.1.3 Compliance obligations: the Australian Consumer Law, and the ACCC’s guides as the regulator’s view of it, should appear in the register for any business that markets environmental claims.
• Clause 7.4 Communication: ISO 14001 requires external communication to be consistent with information generated within the EMS, and reliable. I pick one public claim and ask to see the data it came from.
• Clause 9.1 Monitoring and measurement: who checks that the claim is still true each year, after a new site, a new supplier or a lapsed certificate?
• Clause 7.5 Documented information: are the inventory, the certificate surrenders and the credit retirements kept somewhere that survives a staff change?
• Clause 9.2 Internal audit: have marketing claims ever been in the audit programme? In most systems I see, they have not.

The penalty in the case behind our greenwashing article was not for the wording. It was for a promise to monitor that nobody kept. Emissions claims carry the same risk: the claim is accurate the day it is made, then the business changes and nobody goes back to check.

Five questions to ask before keeping a claim

1. Is the claim carbon neutral, net zero or renewable, and does the wording match which one it is?
2. What boundary does it cover, and would an ordinary reader assume it covers more?
3. If credits are involved, can you name the project, the scheme and the registry, and show they were retired for you?
4. If it relies on Climate Active, what happens to it after 30 June 2027?
5. Who in the business checks it each year, and where is that check recorded?

If any answer is uncertain, the ACCC’s advice is to update the claim, find stronger evidence, or stop making it.

Carbon neutral claims: FAQs

Is carbon neutral the same as 100% renewable?

No. Carbon neutral means net emissions inside a stated boundary are zero, usually after buying carbon credits. 100% renewable usually refers only to electricity being matched by renewable generation or certificates. A business can be one without being the other.

Is Climate Active ending?

The federal government has proposed ending Climate Active certification on 30 June 2027 after a transition period, with its brand, trade marks and carbon neutral standards discontinued. Consultation closed on 18 September 2026 and the final decision is still to be announced.

Can a business still say it is carbon neutral?

Yes, if the claim is accurate and can be substantiated. The ACCC’s October 2026 guide expects sound emissions accounting, transparency about any carbon credits, no double counting and wording that does not overstate what was done. Absolute terms are risky in short-form advertising.

What is ISO 14068-1?

ISO 14068-1:2023 is the international standard for carbon neutrality claims. It expects an organisation to reduce its emissions first and use carbon credits only for the residual, and it is likely to become a common reference point as Climate Active closes.

How Streamline can help

Streamline helps organisations build ISO 14001 environmental management systems in which environmental claims are treated as compliance obligations, traced to their data and checked through monitoring and internal audit. We do not calculate carbon footprints. We check that the system behind a claim will hold up when a customer, an auditor or the ACCC asks for the evidence. Our climate risk assessment service covers the wider picture. If you would like to talk through the claims your business makes, get in touch.

Sources: ACCC media release 119/26 (20 October 2026); ACCC, Making emissions claims to consumers: a guide for business (October 2026); Climate Active, Climate Active certification ending: have your say; DCCEEW, Climate Active program 2026 consultation.