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Climate Claims in Switzerland: New Rules, Greenwashing Risks and Better Communication
Since January 2025, Swiss law requires climate claims to be backed by objective, verifiable evidence. What that means for brands, and how to say more with less risk.
For years, "carbon neutral" was one of the most popular phrases in Swiss marketing. It appeared on products, holidays, deliveries and annual reports. Today it is one of the riskiest.
Switzerland has tightened the rules. Since January 2025, climate claims must be backed by objective and verifiable evidence, and the burden of proof sits with the company making them. For communicators, this raises the stakes: a message now has to persuade and withstand scrutiny.
This guide sets out what changed, which words now carry risk and how to keep communicating with confidence.
Swiss climate claims law: what changed in 2025 and 2026
On 1 January 2025, a new provision in the Swiss Unfair Competition Act (UCA) came into force as part of the revised CO₂ Act. Article 3(1)(x) makes it unfair to make climate-related claims about yourself, your goods or your services that cannot be substantiated by objective and verifiable evidence (Homburger). In practice, the company making the claim must be able to prove it.
On 2 March 2026, the Federal Office for the Environment (FOEN) published an enforcement aid on assessing climate-related information under the UCA (FOEN). Its principle is simple: climate information must be clear, accurate and verifiable. The guidance does not bind the courts. It shows how the authorities read the law, and it is likely to carry significant weight.
The rules reach further than advertising. They apply to business-to-business and consumer communication, and to voluntary and mandatory reporting, including transition plans (Kellerhals Carrard via Mondaq). Banks, insurers and asset managers are covered too, from product documents to investor communication (PwC).
Enforcement is no longer theoretical. The Swiss Fairness Commission has ruled in favour of complainants in numerous greenwashing cases, and SECO has intervened over a "climate-neutral" winter sports advertising claim. Competitors, trade associations and consumer organisations can bring civil actions, and intentional violations can lead to criminal proceedings.
Which climate claims are risky in Switzerland
The guidance draws a sharp line between product claims and company claims. Offsetting can support a claim about a company under strict conditions, with reductions in the value chain first. External carbon offsetting cannot be used to substantiate product-level climate claims.
| Term | What the FOEN guidance means for it |
|---|---|
| Climate neutral, climate positive | FOEN advises against them: their broad climate implications cannot currently be substantiated reliably |
| Carbon neutral, CO₂ neutral | Effectively ruled out for products; for a company, only if hard-to-avoid emissions are fully balanced by removals |
| Net zero | Implies a set target, a reduction pathway and, where relevant, a build-up of removals |
| Climate compensated | Requires specific figures, such as the share of emissions offset, and transparency on the quality of the offsets |
| Climate friendly, green, sustainable, ESG | Need a clear explanation of the nature and extent of the climate benefit wherever climate impact is material |
Sources: FOEN, Homburger, Kellerhals Carrard via Mondaq.
The common thread is vagueness. A word that promises a total outcome, such as neutral, positive or green, invites the question "compared with what, and how do you know?" If the answer is not on the page or one click away, the claim is exposed.
How to communicate sustainability claims without greenwashing
The new rules reward specificity. A precise claim is easier to prove and more persuasive than a sweeping one, so the discipline the law demands is also good sustainability communication.
Replace outcomes with facts. The examples below show how a vague claim can become a precise one without losing its force.
| Instead of saying | Consider saying |
|---|---|
| "Our business is carbon neutral." | "We cut our operational emissions by 35% between 2020 and 2025, verified by an independent auditor." |
| "Our products are climate friendly." | "This product's manufacturing emissions are 28% lower than the previous model's, based on a comparable life-cycle assessment." |
| "We are committed to net zero." | "We aim to cut emissions across our value chain by 50% by 2030, compared with 2020, and we publish our progress every year." |
| "We offset our emissions." | "We fund verified climate projects beyond our value chain, separately from our emission reduction targets." |
The figures are illustrative. Any real claim needs substantiated data, clear boundaries and a recognised method. Specificity alone does not guarantee compliance either: a claim about operational emissions must not leave readers with a misleading picture of the company's wider value chain.
State the scope, the timeframe and the reference point. Say whether a claim covers a product, a site or the whole company, which emissions it includes and which year it compares against. The FOEN asks for essential information to sit next to the claim itself, with detail easily accessible through a link or QR code.
Talk about direction as well as status. A science-based target, a reduction pathway and annual progress are a stronger story than a label, and they stay credible when the numbers move. Where you fund climate projects beyond your own value chain, present them as a contribution alongside your reductions.
Keep the evidence ready. Every published claim should have a file behind it: the data, the method, the standard used and the date it was last checked. If a competitor or a consumer organisation challenges you, that file is your defence.
Avoiding the greenhushing trap
The easiest response to stricter rules is to say nothing. It is tempting, and it is a mistake.
Silence has its own costs. Clients, investors and employees read an absence of information as an absence of action. Companies that are genuinely reducing emissions lose credit for the work, and the market loses the examples that show the transition is possible.
There is a difference between communicating climate action and claiming climate success. A company does not need to have completed its transition to talk about it credibly. It can explain the investments it is making, the obstacles it faces, the progress it can demonstrate and the gaps that remain. Being open about uncertainty helps audiences grasp the scale of the challenge, and it earns more trust than a label.
The new rules are a reason to communicate better. Companies that publish specific, well-substantiated claims are better placed to withstand scrutiny and build trust, and they stand out from competitors who still rely on labels. In a market where vague claims are becoming a liability, precision is a competitive advantage.
A checklist before you publish a climate claim
- Is it specific? Name the scope (product, site or company), the emissions covered and the time period.
- Can you prove it? Hold current data, a recognised method and, where possible, independent verification.
- Is the evidence close to the claim? Put essential information next to it, with detail one click or scan away.
- Does it rely on offsets? If so, it cannot support a product claim, and a company claim must show reductions first.
- Does it use a total word? Neutral, positive, green and sustainable need either strong proof or a more precise alternative.
- Is it consistent? Check it matches your sustainability report, website, sales material and investor communication.
- Would it survive a complaint? Ask someone outside the team to challenge it before it goes out.
Frequently asked questions
Is carbon-neutral advertising banned in Switzerland?
There is no outright ban on the words. Since January 2025, every climate claim must be backed by objective and verifiable evidence. FOEN's guidance effectively rules out "carbon neutral" for products and allows it for companies only under strict conditions.
Can Swiss companies use carbon offsets in climate claims?
At company level, under strict conditions: emission reductions come first, and offsets must be of high quality and disclosed transparently. External offsets cannot be used to substantiate climate claims about products.
Do the new rules apply to financial institutions?
Yes. They cover banks, insurers and asset managers, including financial products, sustainability reporting and investor communication.
Saying less, proving more
Switzerland's new rules ask companies to do what good sustainability communication always required: say what you have done, show how you know and be honest about what is still in progress. The brands that adapt fastest will be the ones whose claims people can trust.
This article offers communications guidance, not legal advice. For specific claims, take advice from qualified counsel.
UNUECO helps companies and financial institutions in Switzerland turn climate and sustainability performance into clear, evidence-based communication, from brand positioning and narrative reviews to content and data storytelling. Explore our services or get in touch.
Sources
Federal Office for the Environment (2026). Climate-related information: new enforcement aid creates legal certainty.
Homburger (2026). New guidance on climate claims under the Swiss Unfair Competition Act.
Hösli, A., Kellerhals Carrard (2026). ESG Desk Newsletter: Avoiding climate-washing, key points for practice. Mondaq.
PwC Switzerland (2026). Climate claims under the Swiss UWG: tighter rules, higher risk for financial institutions.
