Grey is the New Black: Navigating Ambiguity in the Carbon Claims Landscape

Ivy Protocol
7 min readJul 25, 2023

By Ieva Blazauskaite (Marketing Lead, Ivy Protocol)

Over the years, the Voluntary Carbon Market has increasingly attracted public scrutiny. There’s a narrative of skepticism, often portraying carbon credits as nothing more than a ‘golden ticket’ for greenwashing and corporate inaction. But if we sift through the noise and listen to the voices at the heart of this industry, a different picture begins to emerge. Numerous stakeholders are rolling up their sleeves, striving for transparency, enhancing integrity, and drafting standards to scale this market. What drives them? A shared ambition to secure funding for high-integrity carbon projects while adhering to a mitigation hierarchy.

Is ambition alone enough, you ask? Not quite. Ambition needs to be fueled by well-informed action. And that’s why we believe in countering the stifling effects of one-sided criticism by giving equal voice to all perspectives. That includes understanding and navigating the ‘grey area’ of the VCM.

Venturing into the ‘grey zone’ isn’t a walk in the park. It calls for comprehensive research and a bold foray into the intricate labyrinth of industry-specific complexities. The climate clock is ticking, and there’s no room for a shortsighted, polarized approach. We must challenge our beliefs and push for transformative changes which align corporate finances with climate initiatives, thereby supporting global goals.

Navigating Carbon Claims: Why Clarity Matters

In the current scenario, corporate claims wander in a regulatory wildland, where instances of greenwashing are far too common. It’s more than just a marketing tactic — it’s a policy conundrum, as well.

As highlighted in a study by Trouwloon et al. (2023), over 8,296 entities had joined the United Nations-backed ‘Race to Zero’ campaign by February 1st, 2023, and the Science Based Targets initiative has approved science-based targets for 2,217 companies. These businesses now find themselves navigating the often unclear territory of carbon claims. The myriad of choices, ranging from net-zero to carbon-positive and beyond, present a complex decision-making process. It’s as if they are standing at an ice cream parlor, craving a refreshing scoop of ice cream without knowing which flavor to pick. However, the true challenge lies not in satisfying our taste buds, but in taking meaningful action to cool down our planet.

The Mitigation Hierarchy: Why It Matters

Trouwloon et al. (2023) stress the necessity of a defined carbon claims taxonomy, emphasizing that its absence might impede critical actions for greenhouse gas reduction. The VCM must ensure that offsetting isn’t a cheap trick that lets companies pollute freely while hiding behind ambiguous carbon claims. To prevent this — the industry has been steadily cranking up the volume on the importance of the mitigation hierarchy. The aim here is to clarify that offsetting should complement — not replace — emission reductions and other climate initiatives.

Fig. 1. Mitigation Hierarchy. By Ivy Protocol, 2023

The Customer and Climate Action: An Emerging Link

Rising customer demand is another catalyst for a clear claims taxonomy. The Climate Action Awareness Report 2022 shows that most survey participants perceive climate change as a top priority and expect companies to act transparently and share their mitigation strategies.

Mitigating Reputation and Litigation Risks in the VCM

Unambiguous carbon claims are not only crucial for guiding customers but also play a vital role in attracting investors. They help safeguard the reputation and avert climate litigation, giving companies a safe and legitimate path for engaging with the VCM. Delta Air Lines, for example, is currently being sued for the claim of carbon neutrality. While Gucci removed the carbon-neutral claim from its website following a media uproar initiated by The Guardian.

Regulations Rising: A Global Response

In response, stricter regulations are taking shape across the globe. In addition to the launch of the new Corporate Sustainability Reporting Directive (CSRD) by the EU in January, the European Parliament, in May, voted to ban carbon-neutral claims that are based on carbon-offsetting schemes. Meanwhile, the Advertising Standards Authority (ASA) in the UK and the U.S. Federal Trade Commission (FTC) have taken steps for greater transparency, standardization, and regulation.

Strengthening Policies: The Rising Tide

Several NGOs and initiatives are also fortifying the voluntary carbon market policy. Notably, the Integrity Council on Voluntary Carbon Markets (IC VCM) published 10 Core Carbon Principles, and the Gold Standard launched Considerations for Credible Claims, and an initial framework for organizational climate mitigation strategies for further discussion and feedback in 2023. Voluntary Carbon Markets Integrity Initiative (VCMI) launched the long-awaited Claims Code of Practice. The Science-Based Targets Initiative (SBTi) released Corporate Net-Zero Standard and public consultation on Beyond Value Chain Mitigation as the organization develops guidance to help companies go beyond their science-based targets by channeling additional climate finance toward mitigation activities outside of their value chains. This collective action signifies a hopeful shift, an industry striving for clear, credible, and effective carbon claims.

Fig. 2 The Core Carbon Principles. Adapted from ‘The Core Carbon Principles. Plus the Program-Level Assessment Framework and Assessment Procedure’ by IC VCM, 2023, Source

The Potential of Forward Financing

At Ivy Protocol, we’re deeply involved in this evolving industry, developing a platform that bridges the gap between early-stage project developers and upfront funding. By providing capital at the pre-feasibility stage, we enable the developers to undertake necessary activities, propelling them towards the feasibility stage and beyond.

However, amidst this dialogue, one question arises: What does forward financing imply for climate disclosures? Given the nature of forward financing, it does not currently permit carbon offset claims. These claims depend on fulfilling the spot contract, available only after a set delivery date. Yet, we view this early involvement in forward financing as a chance to drive precedent-setting climate action.

The Bigger Picture: Conservation and More

Companies need to view the projects as more than just sources of carbon offsets. They should be seen as opportunities for even greater impact, including biodiversity conservation, job creation, and community development.

This approach offers corporations the chance to set climate precedents, much like Patagonia does repeatedly. Companies can channel their Corporate Social Responsibility (CSR) Funding or philanthropic efforts towards forward financing, contributing to climate action without making explicit carbon claims just yet.

Venturing into Forward Financing

As we embark on new journeys, it’s crucial to learn from past mistakes and avoid greenwashing at all costs. Hence, transparency and robust reporting are paramount to ensure genuine contributions to climate action.

To prevent creating a misleading image about their environmental impact while engaging with forward financing, we suggest brands pay attention to the “gap between ‘symbolic’ and ‘substantive’ corporate social actions (CSA),” as pointed out by Freitas Netto, et al. The paper further classifies claim deceptiveness into five categories (see fig. 3).

Fig. 3 Claim deceptiveness. Adapted from ‘Concepts and forms of greenwashing: A systematic review,’ by S. V. de Freitas Netto, M. F. F. Sobral, A. R. B. Ribeiro, & G. R. D. L. Soares, 2020, Source

Trouwloon et al. (2023) stress the need for enhanced transparency and governance in the area of corporate climate claims to ensure carbon finance effectively contributes rather than hinders global climate goals.

They highlight three dimensions: the clarity around the intended use of the credits, the framing and meaning of headline terms, and the status of the claim, whether it’s an aspirational commitment or an actual achievement. Clarity around these aspects can significantly boost transparency surrounding corporate climate disclosures.

Independent rating agencies, such as Sylvera and BeZero also play a crucial role in ensuring the integrity of the projects.


At Ivy Protocol, our mission is to bridge the chasm between intent and action, connecting pre-certified environmental projects with the necessary funding. We dream of a world where nature’s value is integrated into our economic systems, where transparency replaces ambiguity, and where accountability vanquishes inaction.

As we traverse this journey, we remain hopeful. With consistent policy alignment and iterative regulation evolving alongside the market, we believe that our shared vision of a healthier planet is within our grasp. Join us in our endeavor to reshape the Voluntary Carbon Market landscape and set precedents in climate action.

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Advertising Standards Authority (ASA). (2023). Advertising guidance: Misleading environmental claims and social responsibility. Retrieved from

Carbon Pulse. (2023, June 20). Gucci makes fashion faux pas about carbon neutrality claim. Retrieved from

ClimatePartner. (2022). Climate Action Awareness Report 2022. Retrieved from

Freitas Netto, S. V., Sobral, M. F. F., Ribeiro, A. R. B., & Soares, G. R. D. L. (2020). Concepts and forms of greenwashing: A systematic review. Environmental Sciences Europe, 32, Article 19. Retrieved from

The Guardian. (2023, May 30). Delta Air Lines faces lawsuit over carbon neutrality claim. Retrieved from

The Guardian. (2023, January 18). Revealed: Forest carbon offsets’ biggest provider is ‘worthless’. Retrieved from

EUR-Lex. (2022). Directive (EU) 2022/2464 of the European Parliament and of the Council of 30 November 2022 on corporate sustainability reporting and amending Directive (EU) 2017/1132. Retrieved from

Edie. (2023). EU Parliament votes to clamp down on carbon-neutral claims backed by offsetting. Retrieved from,of%20new%20anti-greenwashing%20rules

Federal Trade Commission (FTC). (2023). Talking Trash: FTC Recyclable Claims Green Guides. Retrieved from

Science Based Targets Initiative (SBTi). (2023). Beyond Value Chain Mitigation. Retrieved from

Science Based Targets Initiative (SBTi). (2023). Net-Zero. Retrieved from

Voluntary Carbon Markets Integrity Initiative (VCMI). (2023). Claims Code of Practice. Retrieved from

Gold Standard. (2023). Fairly Contributing to Global Net-Zero: Initial Framework for Organisational Climate Mitigation. Retrieved from

Integrity Council on Voluntary Carbon Markets (IC VCM). (2023). The Core Carbon Principles. Retrieved from



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