No, if neutrality relies on carbon offsetting outside the value chain: this is one of the practices the directive prohibits in all circumstances. Pending the transposing law, the French Environmental Code already regulates this strictly in advertising: the carbon footprint of the product or service over its life cycle, the reduction pathway and the offsetting arrangements must be published. You may communicate a measured reduction and show the carbon contribution separately.
Read the source article: What is the EmpCo directive? Green claims in 2 minutes