EU regulations affecting climate claims (CSRD, GCD, CRCF)

1. Introduction: Why this matters now

Europe is entering a new era of climate transparency and consumer protection.
Companies must now understand three different regulatory pillars:

• CSRD → Sustainability reporting obligations

• Green Claims rules → Restrictions on what you can say publicly

• CRCF → Future EU rules on certified carbon removals

Each framework has its own timeline and scope. This guide explains:

• What applies today

• What will apply soon

• What is not yet in force

• Which companies are affected

So you can take climate action confidently without risking greenwashing claims.

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2. CSRD – Corporate Sustainability Reporting Directive

Status: ✔ In force now (phased implementation 2024–2028)

Purpose: CSRD requires companies to report their full sustainability impacts, including climate emissions, in a standardized and audited format.

Who must comply and when? 

Under CSRD and ESRS (European Sustainability Reporting Standards), companies must:

• Report gross Scope 1, 2, and 3 emissions

• Publish a transition plan aligned with the EU 2050 climate objective

• Disclose climate risks, dependencies, and financial impacts

• Report climate actions and mitigation efforts outside the value chain (e.g., tree planting)

What CSRD does not do

• It does not allow emissions to be reduced using offsets

• It does not certify or approve offset standards

• It does not regulate climate claims

• It does not require CRCF credits

CSRD = reporting transparency, not offset validation.
Tree-Nation contributions remain fully reportable under CSRD as “climate mitigation outside the value chain.”

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3. Green Claims Rules (GCD + National Laws)

Status: ⚠ Not yet adopted at EU level (as of 2025); future uncertain

BUT: Many countries (France, Germany, Netherlands) already enforce strict national anti-greenwashing laws.

Purpose: The Green Claims Directive aims to ensure that environmental claims are truthful, verifiable, and non-misleading.

What the proposed EU GCD would require (if adopted):

• Ban offset-based “carbon neutral”, “climate positive,” “compensated” claims

• Require third-party verification of environmental claims

• Standardize claim substantiation across the EU

• Regulate environmental labels

Timeline & certainty

• Proposal published: 2023

• Parliament position: 2024

• Commission indicated withdrawal: June 2025 → ⚠ future uncertain

• If revived and adopted: earliest implementation 2027

• National laws apply now, regardless of GCD status

What applies today in practice (very important):

• France: Neutrality claims restricted since 2023

• Germany: Courts have banned misleading “climate neutral” claims

• Netherlands: ACM enforces strict rules on environmental claims

Safe claims today (everywhere):

• “We contribute to climate action.”

• “This website supports reforestation.”

• “This purchase funds climate-action projects.”

Unsafe claims today:

• “Carbon neutral product”

• “Climate positive thanks to offsets”

Green Claims = consumer communication rules.
Status varies: national laws apply NOW; EU directive is delayed/uncertain.

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4. CRCF – Carbon Removal Certification Framework

Status: ✔ Adopted (2024)

BUT: ⚠ Not active yet — no credits exist, no registry exists

Purpose: CRCF creates EU-wide rules for certifying carbon removals, ensuring they are:

• measurable

• additional

• durable

• independently verified

Timeline for activation

• Future: official “neutralisation” of residual emissions
  (ONLY if EU activates this role in future regulations)

• Not used today: CSRD reporting

• Not used today: green claims

• Not used today: corporate climate strategy requirements

Clarification for clients

CRCF matters only for future EU-recognized carbon removals — IF and WHEN those rules become active.

For contributions (tree planting, reforestation, nature support),
VCS and Tree-Nation projects remain acceptable and fully reportable.

CRCF is a future-facing framework. It does not affect your 2025–2027 climate communication.

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5. What companies should do today (2025–2026)

✔ Report transparently under CSRD

Report emissions and contributions clearly, without implying compensation.

✔ Use contribution-based climate language

Safe, positive statements such as:

• “This [product/website] supports climate-action projects.”

• “We contribute to global reforestation.”

• “We help restore ecosystems through Tree-Nation.”

✔ Avoid neutrality/compensation claims

Regardless of CRCF or GCD status, national laws already prohibit these in practice.

✔ Focus on real climate actions

Invest in:

• reforestation

• restoration

• nature-based solutions

• employee engagement

• automated planting triggers

(All above solutions are available through Tree-Nation)

✔ Monitor CRCF developments

CRCF is not active yet, and its future application to corporate net-zero remains uncertain.
Only relevant if your long-term goal includes official net-zero with neutralisation of residual emissions.

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6. Timeline summary

What applies NOW (2025):

• ✔ CSRD reporting framework

• ✔ National anti-greenwashing laws in France, Germany, NL

• ✔ Contribution-based climate communication

• ✔ Tree-Nation contributions fully reportable

What is COMING (2026–2027):

• ✔ CSRD applies to more companies

• ⚠ Possible revival of Green Claims Directive (uncertain)

• ⚠ CRCF methodologies published

• ⚠ First CRCF removal credits (if ecosystem matures)

What is LATER (2028+):

• ⚠ CRCF registry becomes operational

• ⚠ Potential EU recognition of CRCF removals for official “neutralisation”

• ⚠ Future climate-claim rules (EU-wide) may become harmonized

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7. The Tree-Nation position (clear + safe)

Tree-Nation supports companies with:

Climate Contributions

✔ Fully compliant under CSRD
✔ 100% acceptable under national consumer laws
✔ Safe across future EU frameworks

No neutrality claims required or promoted

Tree-Nation emphasizes climate action, not carbon equivalence.

Automation and engagement

Smart planting triggers create meaningful climate engagement without overclaiming impact.

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8. Final recommendations for Companies

✔ Do this

• Adopt contribution-based climate messaging

• Report transparently under CSRD

• Engage customers and employees in climate action

• Document all contributions clearly

• Monitor CRCF developments (for future, not current, use)

❌ Avoid this

• “Carbon Neutral” claims

• “Climate Positive” messaging

• Claims implying offsetting or equivalence

• Using CRCF terminology prematurely

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9. Need support integrating climate action into your business?

Tree-Nation is not a regulatory consultant, but we support companies by providing:

✔ Clear, contribution-based climate communication templates

Easy, safe wording your team can use when describing climate contributions.

✔ Tools to integrate climate action into your website, products, and operations

Including automated planting triggers, checkout integrations, and team engagement tools.

✔ Transparent project documentation

Helpful for CSRD disclosures and sustainability reporting sections on “mitigation outside the value chain.”

✔ Guidance on safe claim practices

We help you understand what types of climate messages are allowed, and how to avoid unintended greenwashing risks.

✔ A simple, authentic way to engage customers and employees

We provide the tools to turn climate action into a meaningful, positive part of your brand experience.

We stay within our role: Tree-Nation provides climate-action solutions and communication support — not legal or regulatory advice.

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10. Continuous updates

EU climate regulations continue to evolve rapidly. We will update this guide every quarter to ensure our clients always have the latest, most reliable information.

Last update: Dec 3 - 2025