Automotive Plants 2026: “Climate Neutral Production” — What’s Still Permitted?

Many car manufacturers advertise individual plants as “climate neutral”. From 27 September 2026, this term will be subject to a per-se prohibition if based on offsetting. The question: what remains permissible?

What is problematic: “Climate neutral plant” through electricity compensation of industrial gases (CO₂ from steel smelting, aluminium die-casting). “Carbon neutral production” with bio-LNG for casting lines. Blanket “green plants” without a concrete Scope 1 balance.

What remains permissible: Genuine Scope 1 reduction: electrification of heat generation, H₂-DRI steel instead of blast furnace, photovoltaic roof systems replacing natural gas CHP plants. Scope 2 reduction: 100% green electricity with certificates of origin (GoO). Scope 3 insetting measures: supplier contracts for green steel, circular aluminium.

Substantiated vs. unsubstantiated — examples to illustrate the legal position: a claim such as ❌ “Climate neutral plant” remains unsubstantiated without a verifiable basis, whereas a specified claim such as ✓ “Plant: Scope 1+2 emissions reduced by X% since the base year (GHG Protocol compliant, ISO-14064 verified)” substantiates the underlying fact. Likewise, ❌ “Carbon neutral production” is unsubstantiated without evidence, whereas ✓ “Production on an SBTi-validated 1.5°C pathway: reduction target by 2030, share of green electricity stated” meets the substantiation requirement.

Particular challenge: Scope 3 (supply chain + use phase). For a passenger car, 80-90% of emissions occur during the use phase. A “green plant” therefore says little about the climate balance of the overall product. Verbraucherzentrale (German Consumer Advice Centre) are increasingly taking legal action against advertising that suggests a “climate neutral plant” while concealing Scope 3.

Conclusion: Concrete plant balance instead of “climate neutral”, with Scope separation and third-party verification. Reduction pathway instead of status claim.