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Digital Product Passports and Carbon Credits: How to Back a Product Climate Claim With Proof

Digital Product Passports and Carbon Credits: How to Back a Product Climate Claim With Proof

A "carbon neutral" label requires a buyer to trust the provider of a product or service. A passport that carries the footprint and links to the retirement record, in contrast, lets them verify the claim.

Pick up a product with a "climate neutral" sticker on it and ask three questions. Carbon neutral compared to what? Measured how? Emissions offset with which carbon credits?

Most labels cannot answer these key questions. That is not because the companies behind them did nothing. Many measured a footprint, bought credits, and retired them. The problem is that the label compresses all of that work into an adjective, and an adjective cannot be audited.

Two things are changing that at the same time. On September 27, 2026, the European Union's Empowering Consumers Directive makes it an unfair commercial practice to claim that a product is climate neutral, reduced, or positive on the basis of offsetting. And on July 20, 2026, the European Commission switched on the central registry for Digital Product Passports (DPPs), the machine-readable record that every product in a regulated group will need before it can be sold in the EU.

So the question is no longer whether a product can carry a climate claim. It is what kind of claim survives a scan.

Key Takeaways

  • A Digital Product Passport (DPP) is a machine-readable record, reached through a QR code or similar data carrier, that holds a product's sustainability data under the EU Ecodesign for Sustainable Products Regulation (ESPR). The EU's DPP registry went live on July 20, 2026, and the first mandatory passports (large batteries) apply from February 18, 2027.
  • The DPP records a product's carbon footprint as a gross life-cycle figure. Currently, the ESPR text doesn't contain a field for carbon credits or offsets, and the EU battery footprint methodology excludes offsets from the declared carbon footprint number. That said, it does allow environmental instruments, like carbon credits, to be reported separately.
  • From September 27, 2026, EU consumer law blacklists any claim that a product is climate neutral, reduced, or positive because of offsetting. However, transparent, specific statements about a company's carbon credit purchases remain permitted.
  • The passport and the retirement record are complementary, not competing. The footprint says what a product emitted. The retirement certificate says what was financed in response. A link between them lets anyone check both.
  • Carbon credits retired per unit, with the product identifier written into the retirement record and the public certificate URL written into the passport, turn a marketing adjective into an auditable line item. Carbonmark's work to increase transparency and traceability for carbon offset actions, via the use of public blockchain technology, is supportive of DPP efforts and helps pave the way for highly auditable environmental claims.

What is a Digital Product Passport?

A Digital Product Passport is defined in Article 2 of the ESPR (Regulation (EU) 2024/1781) as "a set of data specific to a product that includes the information specified in the applicable delegated act... and that is accessible via electronic means through a data carrier."

In plain terms: a QR code, NFC chip, or RFID tag on the product, its packaging, or its documentation, connected to a persistent unique product identifier, opens a structured record about that product. Article 9 of the regulation is blunt about what happens without one. Products in a covered group "can only be placed on the market or put into service if a digital product passport is available."

There are a variety of attributes a passport can hold, depending on the product group:

  • Durability, reliability, and repairability (including a repairability score)
  • Recycled content and material footprint
  • Substances of concern
  • Environmental footprint and carbon footprint
  • Compliance documentation, manuals, and safety information
  • Identifiers for the manufacturer, other operators, and facilities

Three architectural choices matter for what follows. The system is decentralized: the data is stored by the manufacturer or a certified DPP service provider, and the Commission's registry holds only the identifiers. The data must be built on open, interoperable standards, machine-readable and transferable "without vendor lock-in." And the regulation is technology-neutral: the EU-funded CIRPASS project, which drafted the reference architecture, described blockchain as "one current way" to secure identifiers.

Where the DPP rollout stands as of September 2026

MilestoneDateStatus
ESPR enters into forceJuly 18, 2024Done
First working plan names priority groups: iron and steel, aluminium, textiles, furniture, tyres, mattressesApril 2025Done
Six CEN/CENELEC DPP standards (identifiers, data carriers, APIs, interoperability, storage, exchange protocols) cited as harmonized standardsJuly 15, 2026Done
EU DPP registry live, with testing environment and APIJuly 20, 2026Done
Iron and steel delegated act (first product DPP, with carbon footprint and performance classes)Expected Q4 2026Consultation closed August 2026
Battery passports mandatory for EV, light-transport, and industrial batteries above 2 kWhFebruary 18, 2027Fixed in law
Textiles, aluminium, and tyres delegated acts2027 (indicative)Pending
Furniture; then mattresses and ICT products2028; 2029 (indicative)Pending

The EU is not alone. The UN Transparency Protocol (UNTP) from UN/CEFACT is a passport-plus-credentials standard designed so that national schemes can build on it. The UK opened a call for evidence on "digital product records" in July 2026. Japan's Ouranos Ecosystem has already exchanged battery carbon footprint data with Europe's Catena-X network, and China stood up a national DPP working group in March 2026. ABI Research has forecast that more than 62.5 billion apparel DPPs will be issued in 2030 alone. Treat that as an analyst forecast, not a certainty, but the direction is not in doubt.

What a DPP says about carbon, and what it leaves out

The carbon footprint is one of the named parameters a delegated act can require. The ESPR defines it as "the sum of greenhouse gas emissions and greenhouse gas removals in a product system, expressed as CO₂ equivalents and based on a life cycle assessment using the single impact category of climate change." The methods behind it are the EU's Product Environmental Footprint (PEF) or "other scientific methods," which in practice means ISO 14067, the international product carbon footprint standard.

The battery passport, the first one to go live, shows what this looks like in detail. The declaration is expressed in kg CO₂e per kWh of energy delivered over the battery's service life, broken down by raw material acquisition, production, distribution, and end of life, with a public link to the underlying study. The iron and steel proposal goes further still: the Commission's Joint Research Centre designed its footprint declaration to be interoperable with construction-sector Environmental Product Declarations and with the data the EU's Carbon Border Adjustment Mechanism (CBAM) already collects.

There is, however, a purposeful absence in language around carbon offsetting under the current framework: if you search the full text of the ESPR for "offset" or "carbon credit" you get zero results. The regulation's carbon concept is a life-cycle inventory, nothing more. The methodology drafted for battery footprints states that calculated offsets shall not be included in the carbon footprint declaration, though they can be reported separately as supplementary environmental information. The automotive industry's Catena-X PCF Rulebook, which many suppliers will use to feed passports, is explicit: "Any GHG offsets... shall be excluded from the reported PCF... the supplier... shall report any offsets separately from the PCF." ISO 14067 itself puts offsetting outside its scope.

This is a feature, not a gap. The passport is a gross-emissions ledger by design. It cannot be netted down. Whoever scans it sees the real number.

Importantly, the passport tells you what the product emitted. It does not, however, tell you what anyone did about it.

Where carbon credits come in

A carbon credit represents one tonne of CO₂e avoided or removed by a verified project and issued under a registry such as Verra, Gold Standard, Puro.earth, or the International Carbon Registry (ICR). Retirement is the moment a credit is permanently taken out of circulation and assigned to a named beneficiary. After retirement the tonne cannot be sold or claimed again. On Carbonmark, such retirement claims are registered on a public blockchain and tied to immutable certificates, as well as communicated back to host carbon registries on a 1:1 basis, where supported. As carbon registries build out their own APIs and move toward blockchain technology (as is the case with e.g. Gold Standard, ICR, EcoRegistry, and others), the link between a credit and a retirement claim made against it, as well as the ability for third parties to monitor the provenance of credits, will continue to be made more robust.

Regarding usage, credits sit at the end of the mitigation hierarchy: avoid, reduce, replace, compensate. The international standard for carbon neutrality, ISO 14068-1:2023, which replaced the withdrawn PAS 2060 on January 1, 2025, encodes the same order. Quantify the footprint (ISO 14067 for products), reduce it along a documented hierarchy, then counterbalance what remains with credits that meet quality criteria, retire them, and report.

Critically, the footprint and the retirement are two different records describing two different facts.

Product carbon footprint (in the DPP)Carbon credit retirement (in a registry or onchain)
What it recordsGreenhouse gases emitted across the product's life cycleTonnes of CO₂e financed to be avoided or removed elsewhere
Who produces itThe manufacturer, per ISO 14067 or PEF, verified by a third partyThe registry, at the moment the beneficiary retires the credit
Can it be netted?No. The methods exclude offsetsNot applicable. It is the compensating entry
Where it livesThe passport, hosted by the operator or a DPP service providerA public registry record, or an onchain certificate
What links themThe unique product identifierA retirement record that names that identifier

Today those two records almost never reference each other. The footprint lives on a label or in a sustainability report. The retirement certificate lives in a PDF on a shared drive. The DPP is the first mandated structure that can hold a pointer from one to the other.

There is a second reason to keep them linked. The GHG Protocol accepts that Scope 3 emissions are counted by more than one company along a value chain, but it draws a hard line at credits: "double counting is a problem when it comes to offset credits or other market instruments that convey unique claims to GHG reductions or removals." A retirement record that names the product it was retired for is the simplest defense against the same tonne being claimed twice.

The rule that changes on September 27, 2026

Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive, adds new entries to the EU's blacklist of commercial practices that are always unfair, with no case-by-case test. The one that matters here is point 4c:

"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."

The directive's recitals give examples of the wording it targets: "climate neutral," "CO₂ neutral certified," "carbon positive," "climate net zero," "climate compensated." Two neighboring entries also bite. Point 2a bans sustainability labels not based on a certification scheme or established by public authorities. Point 4a bans generic environmental claims such as "eco-friendly" or "green" without recognized excellent performance to back them.

What the directive does not ban is as important. The Commission's own Q&A, updated in June 2026, states that the prohibition "does not apply to claims based on offsetting at company level" and "does not prevent companies from communicating about their investments in environmental initiatives, including carbon credit projects, provided this information is presented transparently and is not misleading."

In other words: buying and retiring credits stays legal. Calling the product neutral because of them does not.

One more constraint, and it applies directly to passports. A QR code does not rescue an ambiguous headline claim. Germany's Federal Court of Justice ruled in the Katjes case (June 2024) that the meaning of "klimaneutral" must be explained in the advertisement itself, not through a QR code or a link to the certifier's website. The UK Competition and Markets Authority said the same in its May 2026 supply-chain guidance: key qualifications "should not be buried in QR codes or secondary pages." Since April 2025 the CMA can fine a business up to 10% of global turnover for a misleading claim without going to court. In California, AB 1305 requires any company making a carbon neutral or net zero claim to post online the seller, registry, project ID, protocol, and verification status of the credits it relied on.

So the passport is where the proof goes. The claim on the pack has to stand on its own, and after September 27 it cannot be a neutrality adjective.

❌ "This jacket is climate neutral. Scan for details."

✅ "Life-cycle footprint: 12 kg CO₂e (cradle to grave, ISO 14067, third-party verified). We retired 12 kg of CO₂e in Core Carbon Principles-labelled credits from [project] on [date]. Certificate: [public link]."

The second version makes no promise about neutrality. It states two facts and hands over the evidence for both.

What happened to the brands that kept the adjective

Apple marketed the Apple Watch Series 9 as "carbon neutral": a 75% emissions reduction plus forestry credits in Paraguay and Brazil. In August 2025 the Regional Court of Frankfurt banned the claim in Germany. The court's reasoning was about time: most of the Paraguayan eucalyptus leases run only to 2029, while a consumer reads "neutral" as lasting far longer. In October 2025 Apple stopped labelling the Watch Series 11 and the Mac mini as carbon neutral, citing the incoming EU rule. A parallel US lawsuit was dismissed in February 2026 because the plaintiffs could not show the claim was false.

Read that sequence carefully. Apple's reductions were real and its credits were retired. The claim still failed, because "neutral" promised something the underlying records did not support.

The pattern repeats. A Paris court found Danone's "neutre en carbone" claim on Volvic bottles misleading in June 2026. Nestlé dropped carbon-neutral pledges for KitKat and Nespresso in June 2023. Gucci removed its "entirely carbon neutral" claim in May 2023. Each of these companies had bought credits. None of them had a record the buyer could open.

Five ways a DPP strengthens a product climate claim

1. One scan, both records

The passport carries the gross footprint because the law requires it. It can also carry, as supplementary environmental information, the link to the retirement record. The buyer sees what the product emitted and what was retired, side by side, with neither number hiding the other.

2. Item-level matching

Each delegated act decides whether a passport is issued per model, per batch, or per item. Battery passports are per item. Where the passport is per item, the retirement can be too. The Carbonmark API retires from 0.001 tCO₂e (1 kg), which means a per-unit retirement is realistic for a T-shirt, not only for an EV battery. Write the product identifier into the retirement message, write the certificate URL into the passport, and the link runs in both directions.

3. Independent verifiability

A registry record carries serial numbers. An onchain certificate carries a transaction hash that cannot be edited after it confirms. Either can be opened by a regulator, a journalist, or a competitor without asking the brand's permission. The UN Transparency Protocol makes this the default for every sustainability claim in a passport: each claim "MUST" reference an independent conformity assessment and the evidence "SHOULD be digitally verifiable." Credits deserve the same treatment. Link to the retirement, not to a PDF of it.

4. Protection against double claiming

A retirement whose beneficiary field names the product, batch, or serial cannot quietly be reused for a corporate inventory claim or sold on to someone else. Verra added a "corporate emissions inventory accounting" retirement reason in October 2023 precisely so the intended use of a retired credit is visible. A product identifier in the retirement record does the same job at product level.

5. Honesty about time

The ESPR requires a passport to remain available for at least the product's expected lifetime, and delegated acts set out how it is updated. That solves the problem that sank the Apple Watch claim. A passport that shows the credit's vintage, the project's crediting period, and the retirement date states what was done and when. It does not promise "forever." And if a company retires additional credits in later years, the passport can record that too.

What this looks like in practice

Be clear about where the market actually is. Volvo's EX90 battery passport, built with Circulor and launched in June 2024, opens from a QR code on the door frame and shows raw-material provenance and the pack's embedded carbon footprint. It shows no credits. Pangaia's EON passports (2021) showed which offsetting scheme applied to a garment, but not a retirement record. Carbonmark is actively working with industry stakeholders integrating digital product passports to provide the first wave of carbon compensation information into these systems. While it's still early days, much of the foundational work is now in place to move these initiatives forward.

Here's an illustration of what such an integration may look like for an apparel brand:

  1. Measure. Calculate the garment's cradle-to-grave footprint per ISO 14067, exchanged in the WBCSD PACT format so suppliers' data flows in consistently. Say it comes to 14 kg CO₂e.
  2. Reduce. Switch the dye house to renewable electricity and raise recycled fiber content. The verified footprint falls to 12 kg CO₂e. That figure, not the original, goes into the passport.
  3. Retire the residual, per item, at the point of sale. Request a quote for 0.012 tCO₂e, then place the order with the brand as beneficiary and the garment's unique product identifier in the retirement message.
  4. Write the proof back. The order returns a transaction hash and a public certificate URL. Store the URL in the passport's supplementary environmental information alongside the footprint.
  5. Word the claim as facts. On the label and the product page, state the footprint, the standard, the tonnes retired, and where to check. No neutrality adjective.

Every step in that list is available today. The first two are required by the incoming regulation anyway. The last three are what turn a compliance record into a credible one.

What this means for you

If you sell products in the EU: audit every climate claim on packaging and product pages before September 27, 2026. Remove neutrality language based on offsetting. Start building ISO 14067 or PEF footprints for your priority product groups now, because the passport will demand them within two to three years regardless of what you say about credits.

If you build DPP software: add a field for retirement records. Your customers will need somewhere to put the proof, and a link to a registry entry or onchain certificate is the difference between a passport that documents a claim and one that merely repeats it.

If you buy from suppliers: ask for the passport and the retirement record together. Check that the identifier in one matches the identifier in the other. A supplier who can show both has done the work.

How Carbonmark fits

Carbonmark exists to make the retirement half of this picture as verifiable as the footprint half.

  • The Carbonmark API runs the flow described above: discover projects, fetch a price, create a quote, place a retirement order, and confirm it. A completed order returns an onchain transaction hash, a block-explorer link, and a public Carbonmark certificate URL. The certificate cannot be edited after the retirement confirms, and its provenance view exposes the registry serial numbers, so a reader can trace the tonne back to its issuance. The beneficiary_name and retirement_message fields are free text, which is where a product identifier or passport link belongs.
  • Fractional retirement from 1 kg makes per-item retirement viable for low-footprint goods. Retirements settle on Polygon and Base, and API v20 has been the latest stable release since August 17, 2026.
  • The Marketplace lists 150+ verified projects across 25+ countries, filterable by registry, methodology, geography, and co-benefits, so the credits behind a product claim can be chosen for quality rather than convenience. Roughly 115 million credits have been approved to carry the Integrity Council's Core Carbon Principles label since March 2024; a claim built on labelled credits is easier to defend.

If you are planning a passport rollout and want the retirement record designed in from the start, talk to the Solutions Team.

Frequently asked questions

What is a Digital Product Passport?

A Digital Product Passport (DPP) is a structured, machine-readable set of data about a specific product, accessed through a data carrier such as a QR code, NFC chip, or RFID tag linked to a unique product identifier. Under the EU Ecodesign for Sustainable Products Regulation, products in covered groups cannot be sold in the EU without one. The passport can hold durability, repairability, recycled content, substances of concern, and carbon and environmental footprint data.

Does a Digital Product Passport include carbon offsets or carbon credits?

Not as a required field. The ESPR text does not mention offsets or carbon credits, and the footprint methodologies behind DPPs (ISO 14067, PEF, and the EU battery rules) exclude offsets from the declared carbon footprint. Offsets can be reported separately as supplementary environmental information, which is where a link to a carbon credit retirement record belongs.

Can I still call a product "carbon neutral" in the EU after September 2026?

Not if the claim is based on offsetting. From September 27, 2026, Directive (EU) 2024/825 blacklists any claim that a product has a neutral, reduced, or positive greenhouse gas impact because of offsetting. Companies may still communicate transparently about their carbon credit purchases and company-level climate strategy, provided the statements are specific and not misleading.

How can carbon credits be linked to a Digital Product Passport?

Retire credits with the product's unique identifier (or batch) written into the retirement record, then store the public retirement certificate URL in the passport alongside the product carbon footprint. The passport shows the gross footprint, the retirement record shows the tonnes financed, and the shared identifier lets anyone confirm that the two refer to the same product.

When do Digital Product Passports become mandatory?

The first mandatory passports apply to EV, light-transport, and industrial batteries above 2 kWh from February 18, 2027. The iron and steel delegated act is expected in late 2026, with textiles, aluminium, and tyres indicated for 2027, furniture for 2028, and mattresses and ICT products for 2029. Obligations typically begin 18 to 24 months after each delegated act is adopted.

How can a consumer verify that a carbon credit was actually retired?

Open the retirement record itself. Registries such as Verra and Gold Standard publish retirement entries with serial numbers. Onchain retirements, such as those made through Carbonmark, return a public certificate and a transaction hash that cannot be edited after confirmation, and the certificate's provenance view shows the registry serial numbers behind the tonne.

Related reading

Sources

All accessed September 8, 2026.

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