Saying « neutre en carbone » (carbon neutral) in a creator video costs a public proof. French law makes that sentence conditional on a file any viewer has to be able to consult, and a brand that has not put it together before the shoot has no use for the video it has just paid for.
Three decisions remain: which words to authorise in a script, what to hand the creator to support them, and what to do when they use them unprompted. The formats and the profiles that work in this category are covered in the guide to UGC campaigns for sustainable brands; here it is only a question of words and images.
Three texts that stack and do not ask the same question
An environmental claim is governed not by one text but by three, and they do not ask the same question.
Loi n° 2021-1104, known as loi Climat et résilience, specified by décret n° 2022-539 and codified at article L229-68 of the code de l'environnement (the French environmental code), does not ask whether the sentence is accurate: it asks what the advertiser makes public to support it. Presenting a product as carbon neutral without those elements is prohibited, even when the internal calculation is beyond reproach.
Loi n° 2020-105, known as loi AGEC, codified at article L541-9-1 of the same code, asks nothing: it prohibits certain wordings on a product or its packaging, whatever the evidence. The code de la consommation (the French consumer code), through misleading commercial practice, judges the impression left on the consumer rather than the letter: a figure that is true for the packaging, presented as if it held for the product, becomes misleading.
Hence the consequence that surprises marketing teams: a sentence can be true and prohibited. The first text conditions, the second prohibits, the third appraises.
« Fabriqué en France » is not an environmental claim
Origin falls under the rules on origin claims, whereas an environmental claim bears on an effect on the environment. The two get confused on set, because the short supply chain sells as an ecological argument. As long as the sentence is limited to the place of manufacture, this guide does not apply and the trap is elsewhere, in the assembly in France of an imported product. As soon as it draws an environmental benefit from the origin, "made in France, therefore less transport", it goes back through the three filters.
The prohibited words, even when true
The loi AGEC prohibits placing on a product or its packaging the wordings « biodégradable » (biodegradable) and « respectueux de l'environnement » (environmentally friendly), along with any equivalent wording. The word that counts is "equivalent": it catches « écologique », « vert », « bon pour la planète », as soon as the formula presents itself as an overall quality rather than a verifiable characteristic.
The prohibition targets the product and its packaging, not the soundtrack of a video, and it gets there by two routes. A wording that cannot appear on the packaging does not become lawful because a close-up shows it. And the same sentence, spoken by a creator in a paid video, is a commercial claim appraised on the impression it leaves. The operating rule fits on one line, do not have someone say what you are not allowed to print, and on an online store it holds for the product page, the video and the advertising that picks it up.
The words that require a file reachable from the video
Other wordings are not prohibited, they are conditional, and the condition bears on what a third party can verify without contacting the brand.
« Neutre en carbone » and its equivalents, « zéro carbone », « impact nul », « intégralement compensé », presuppose that the advertiser makes publicly accessible a greenhouse gas emissions assessment for the product, the reduction pathway it is following and the arrangements for offsetting residual emissions. The décret sets the exact form and the update frequency, and it is the text to open before settling on a vocabulary. The word to keep in mind for a brief is "accessible": the file does not sleep in the sustainability director's drawer, it is published on the day the video is shot.
« Recyclé » (recycled) only means something with a rate and a perimeter: a bottle whose body alone contains any is not told in a single word.
« Recyclable » commits on end of life, and the question is not the theoretical recyclability of the material but the existence of a collection stream accessible to the audience addressed.
That leaves making the file reachable from a vertical video: a single stable public page on the brand's domain, at a short address, burnt in on screen when the claim is spoken and repeated in the description. Not a page that closes with the campaign while the video goes on circulating.
| Claim | Governing text | What decides its use | What to do instead |
|---|---|---|---|
| « Biodégradable » | Loi AGEC, article L541-9-1 of the code de l'environnement | Prohibition, on a product as on packaging | Remove the wording from the product, the packaging and the script |
| « Respectueux de l'environnement » | Loi AGEC, article L541-9-1 | Prohibition, equivalent wordings included | Remove the wording, neighbouring formulations included |
| « Neutre en carbone » | Décret n° 2022-539, article L229-68 of the code de l'environnement | Public file: assessment, reduction pathway, offsetting arrangements | Publish the file before distribution, or remove the wording |
| « Recyclé » | Code de la consommation, article L121-2 | A verifiable rate and a named perimeter, product or packaging | Give the rate and the perimeter, or remove the wording |
| « Recyclable » | Code de la consommation, article L121-2 | A collection stream accessible to the audience addressed | Name the available stream, or remove the wording |
Offsetting, which makes nothing neutral
Buying carbon credits reduces an accounting entry, not emissions. The text puts offsetting last, after the assessment and the pathway: it does not replace the other two. A brand that offsets with no reduction pathway does not have an incomplete file, it has a file that says the opposite of the video. And a creator explaining that the brand plants trees turns an accounting operation into an argument for neutrality.
What the image asserts without saying it
The ARPP Développement durable recommendation (ARPP is the French advertising self-regulation body) is a professional rule, not a law, but it targets what no script contains: the image. A forest in the background, a leaf in a transition, a wash of greens on a product with nothing plant-based about it, a planet pictogram invented for the occasion, a kraft box filmed as proof. Each of them asserts something, appraised like the rest of the message.
The most frequent case remains the packaging shot, which makes legible a wording the script never speaks. Reread packaging on a freeze frame, the way you reread a script.
The in-house label
A badge designed by the brand, an internal score, an engagement sticker on the product page: none of that is a certification, and nothing prohibits creating one. The problem arises when the badge is filmed as if it were one. The question, in front of the storyboard: does a viewer who sees this sign for two seconds believe a third party has verified something? If so, name that third party on screen or drop the sign.
What the 2024 European directive will change
Directive (UE) 2024/825 tightens three things. Generic environmental claims used on their own, with no detail on the performance they cover, become unfair practices. Claims based on offsetting to assert that a product has a neutral, reduced or positive effect are targeted head-on. And sustainability labels resting neither on a certification scheme nor on a public authority fall into the same regime as the in-house label.
The state of French transposition has to be checked on the date you read this page: the timetable is in the European text linked at the end of the article and is not deduced from a guide. What is decided without waiting is the writing of scripts for a campaign that will run for several quarters, drafted as if the rule already applied.
The video online on the day the rule changes
A video is not a post, it is an asset that goes on running in paid media, on a product page and on the creator's account. When a rule moves, the brand controls its own surfaces and not the creator's, unless the contract provides a right of withdrawal or re-edit. That clause is negotiated at the quote stage, when it costs nothing.
The penalty is calculated on the budget, not on the creative
When a misleading commercial practice rests on an environmental claim, the ceiling of the fine can be raised in proportion to the spend committed to the advertising concerned. The risk is therefore not measured by the cost of the creative but by the cost of its distribution: a video produced on a modest budget, pushed behind a large media buy, exposes the brand to a ceiling calculated on the second. Carbon neutrality also has its own penalty in the code de l'environnement.
The advertiser answers for what it ordered, the creator for what they publish in their own name. The thresholds are in the code de la consommation, at article L121-2 linked at the end of the article; what does not move is the proportionality to the media budget.
The brief: proof sheet and banned words
A proof sheet is not a list of sentences: every usable claim is tied there to the document that supports it. What the brand sends with the product:
- The usable claims, each with the document that justifies it and its perimeter, product or packaging.
- The claims set aside, with the reason in one line, because a creator who understands why does not reintroduce the word while improvising.
- The address of the public page, in the exact form to be burnt in.
- The name of the person who approves a modified script, with a stated response time.
- The instruction on packaging shots, naming the faces that may be filmed.
That leaves separating what the creator says in their own name from what they assert on behalf of the product. Their feeling, the use they observed, what they replaced, what bothered them in the first weeks: that belongs to them and is filmed without a file. A property of the product, a rate, an overall effect, an end of life, a neutrality: nothing becomes sayable because the sentence opens with "I find that". A creator often uses the word set aside out of conviction rather than carelessness, and the document alone does not stop them: the instruction is repeated out loud before the shoot. Who answers depending on the publication surface is settled at the same moment, in the UGC brief in France.
Sources
- Loi n° 2021-1104 du 22 août 2021 dite Climat et résilience
- Décret n° 2022-539 du 13 avril 2022, allégations de neutralité carbone dans la publicité
- Code de l'environnement, article L229-68
- Ministère de la Transition écologique, Les allégations environnementales
- DGCCRF, Allégations environnementales : ce qu'il faut retenir
- Directive (UE) 2024/825 sur les allégations environnementales et les pratiques commerciales déloyales
- Code de la consommation, article L121-2
- ARPP, Recommandation Développement durable
- ADEME, Guide anti-greenwashing, édition 2025
Checked on 19 September 2026. This guide is not legal advice. Where this guide and the official source disagree, the official source prevails.
