Note: This advice is given by the CAP Executive about non-broadcast advertising. It does not constitute legal advice. It does not bind CAP, CAP advisory panels or the Advertising Standards Authority.
The ASA and CAP’s Climate Change and the Environment (CCE) project is in place to respond to the ongoing climate crisis, and to take action to ensure that environmental claims in advertising are not misleading or irresponsible. Updates about our work in this area are published here.
Rule 11.1 of the CAP Code requires that “the basis of environmental claims must be clear. Unqualified claims could mislead if they omit material information.”. The meaning of all terms used in ads must also be clear to consumers.
The ASA's research on environmental claims in advertising found that there was little consensus about the meaning of certain environmental terms. In particular, “carbon neutral” and “net zero”, or similar, were often used interchangeably and lacked a universally known definition. Some participants in the research tended to believe that carbon neutral claims implied that an absolute reduction in carbon emissions had taken place or would take place.
In light of this, CAP Guidance sets out that marketers should avoid using unqualified “carbon neutral” or “net zero” claims. Information explaining the basis for such claims helps consumers to understand them fully, so this key information should not be omitted from ads.
When making “carbon neutral”, “net zero” or similar claims, marketers should:
- set out the basis of claims clearly and avoid unqualified claims
- make clear whether the claims relate to carbon offsetting or to actively reducing carbon emissions, and to what extent
- provide information about any offsetting scheme used
- ensure claims on future goals are based on a verifiable strategy
- avoid implying that products or their manufacture generate no or few emissions, if that is not the case
In 2023, the ASA investigated a complaint that the claim “Carbon Neutral business” in an ad for Charles Tyrwhitt failed to make the basis of the claim clear. The marketer said they had based their claim on a report by a sustainability consultancy which they said demonstrated their carbon neutrality. The ASA considered consumers would understand from the ad that the business balanced the amount of carbon emitted into the atmosphere by an equivalent amount removed, so purchasing a Charles Tyrwhitt product would have a net neutral impact on carbon emissions. The ASA considered the ad had not included any qualifying information about the basis of the “carbon neutral” claim, and as that was significant information that consumers needed to fully understand the claim, it concluded that the ad was misleading. (Charles Tyrwhitt Shirts Ltd, 20 December 2023).
On the same date, the ASA also ruled against an Instagram post by Brewdog which included the claims “Beer for your Grandchildren. From the World’s First Carbon Negative brewery.” and “positive planet certified carbon negative company”. The ASA considered consumers would likely understand from the ad that Brewdog was a carbon negative business which had the net effect of removing more carbon from the atmosphere than they emitted, and that “beer for your grandchildren” reinforced that impression. Although the ad linked to information on Brewdog’s website about their carbon reduction and offsetting project, the ASA considered that there was no information provided in the ad itself which outlined the basis of the “carbon negative” claims. For that reason, the ASA concluded the ad was misleading. (BrewDog plc, 20 December 2023).
Additionally, in 2020, the ASA upheld a complaint about a radio ad for Shell’s ‘Go+’ loyalty scheme, featuring the claim “Drive carbon-neutral”. The ASA considered the ad implied that Go+ was a fuel for which Shell would offset the carbon emissions related to that fuel purchase, such that the customer could “Drive carbon-neutral”. Because that was not the case, and the ad did not contain anything which might indicate to listeners that what was being advertised was a loyalty programme, the ASA ruled the ad was misleading. (Shell UK Ltd, 08 July 2020).
Also see further ‘environmental’ AdviceOnline entries in the Resource Library, including ‘Environmental claims: General’, ‘Environmental claims: General “Green” claims’ and ‘Travel marketing: Environmental claims’.