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.  

Marketers should always ensure that they hold robust substantiation for any objective claims they make (Magnatech Technology Ltd, 25 May 2022, Supergroup Internet Ltd, 03 December 2025). In addition to a rule requiring the substantiation of claims (Rule 3.7), the Code has a specific section on Environmental Claims (Section 11).

Full life cycle claims

Rule 11.4 states “Marketers must base environmental claims on the full life cycle of the advertised product, unless the marketing communication states otherwise, and must make clear the limits of the life cycle. If a general claim cannot be justified, a more limited claim about specific aspects of a product might be justifiable. Marketers must ensure claims that are based on only part of the advertised product’s life cycle do not mislead consumers about the product’s total environmental impact.”

A product’s full lifecycle includes everything from the inputs in production (such as energy, raw materials or ingredients), to packaging, transport, active use, and finally, disposal. Broad environmental claims, such as “good for the planet”, are usually understood to relate to the impact of a product’s full life cycle. So, unless a broad claim is clearly limited, it should be based on evidence that relates to the product’s entire life cycle. If a claim relates only to certain aspects of a product’s life cycle, or to a particular product component, the claim should be limited and qualified to reflect that.

An ad for an electric scooter which included the claim “be environmentally…friendly” was ruled to be misleading and in breach of rule 11.4. The advertiser argued it was an implicit comparative claim and provided evidence to show the scooter had less of a negative impact on the environment than alternative methods of transport, however they had not demonstrated it caused no environmental damage at all. The ASA concluded that the claim was likely to be understood as absolute, suggesting the scooter caused no environmental damage over its full lifetime. (TIER Operations Ltd, 6 April 2022).

In 2026, the ASA also investigated claims for a baby product company including “Eco nappies & wipes” and “better for our world”. It considered that, in that context of the ad, “eco” was an absolute claim suggesting the products would cause no environmental harm throughout their life cycle. As the ASA had not seen evidence to that effect, it concluded the ad had given a misleading impression of the products’ environmental impact. (Kit & Kin Ltd, 4 February 2026).

Additionally, the ASA ruled against the claim “sustainable” in an ad for a hybrid Mazda car. The marketer said “sustainable” was intended to communicate the efficiency of the Mazda2 Hybrid in comparison to the non-hybrid model. However, the claim had not been qualified to make that basis clear, and the ASA had not seen evidence based on the full life cycle of the car to support the absolute claim “sustainable” as it would be understood by consumers. The ASA considered the ad had misleadingly minimised the environmental impact of the Mazda2 Hybrid. (Mazda Motors UK, 25 September 2024).

In 2013, a promotion headed "WIN GENUINELY GREEN PRIZES WITH NOUVELLE SOFT", featured the claim "We're offering you two chances to win one of our 5 brand new Volkswagen Camper Vans, all of which have an engine meeting stringent Euro V emission levels…". The ASA ruled the ad breached the Code because the advertiser could not demonstrate that the camper vans would cause no environmental damage, taking into account their full life-cycle. (Georgia-Pacific GB Ltd, 30 January 2013).

Making the basis of claims clear and material information

The Code requires that the basis of environmental claims must be clear, and unqualified claims could mislead if they omit material information (Rule 11.1). The meaning of all terms used in marketing communications must also be clear to consumers (Rule 11.2).

In 2026, the ASA considered claims on a website for a baby product company including “sustainable bamboo”, “100% sustainable bamboo fibre”, and “kinder to the planet”. The ASA understood the claims were intended to relate to the bamboo component of their products, which they said had a lower environmental impact than widely-used alternatives. However, as that information had not been included in the ad, the ASA considered that the claims were absolute in nature without further qualification. In the absence of evidence relating to the full life cycle of the bamboo in each product, the ads were considered misleading. (The Cheeky Panda Ltd, 04 February 2026). 

Advertisers should also take care not to mislead by omitting information about their environmental impact. Complaints about two posters for a bank were upheld because they omitted significant information about the brand’s contribution to greenhouse gas emissions (HSBC UK Bank plc 19 October 2022). One ad included the claim that the bank was “aiming to provide up to $1 trillion in financing and investment globally to help…clients transition to net zero”. The second highlighted that the bank was “helping to plant 2 million trees, which [would] lock in 1.25 million tonnes of carbon over their lifetime.”

The ASA concluded that these unqualified claims, while accurate in isolation, were misleading. The ads had not made clear that the advertiser was also involved in financing businesses which made significant contributions to carbon dioxide and other greenhouse gas emissions, and that it would continue to do so for many years into the future. The ruling noted the emissions (more than 65.3 million tonnes) which were produced by businesses financed by the bank’s investment. The ruling also highlighted that natural world imagery which accompanied these claims, in particular imagery of waves crashing onto a beach, contributed to the impression that the advertiser was making a meaningful contribution towards reducing greenhouse gas emissions.

Exaggeration and ambiguity

Marketers should hold robust substantiation for any “green” environmental claims they make. To avoid the risk of exaggeration, marketers should be wary of making absolute claims, as they might have the effect of implying a product or service causes no environmental impact over its full life cycle, unless an ad states otherwise. Comparative claims such as “cleaner” and “greener”, or more limited, qualified claims are more likely to be justifiable and demonstrable with evidence (Rule 11.3).

For many products, it will likely be difficult to prove with evidence an absolute claim suggesting there is no negative impact on the environment, or that there is an actively positive impact. Claims like "The greenest stoves on earth” are also likely to be almost impossible to substantiate. (Clearview Stoves Lt, 11 April 2012).

The ASA investigated an ad for a clothing retailer which made the claim “sustainable clothing”.  It considered that without qualification the claim “sustainable” was ambiguous and unclear. As the “sustainable” claim was also absolute in nature, the ASA considered it was likely to be understood to apply to all Lacoste Kids clothes across their entire life cycle, and so a high level of substantiation in support was needed. The marketer had not provided evidence to demonstrate that their products had no detrimental effect on the environment over their entire life cycle, therefore the ad was considered likely to mislead. (Lacoste E-Commerce, 3 December 2025).

In 2021, the ASA also ruled against an ad for dairy-free milk alternatives which included the absolute claim “good for the planet”. Whilst it acknowledged the ad also included the claims “recipe to a healthier planet” and “deliciously plant based”, the ASA considered it was not clear that these were intended to clarify the claim “good for the planet.” The ruling noted that the claim was open to interpretation: it could be understood as a comparison with equivalent dairy products, or that there was a net positive environmental benefit derived from producing the advertised products. It concluded that the claim was ambiguous and therefore breached rule 11.1, which requires that the basis of environmental claims must be clear. (Alpro (UK) Ltd, 20 October 2021).

Claims about environmental initiatives

When communicating about initiatives or innovations designed to reduce environmental impact, marketers should be careful to avoid giving a misleading impression about the wider environmental impact of the business. This is particularly important where the business is otherwise responsible for a significant amount of ongoing emissions or environmental harm.

When ads highlight initiatives designed to reduce environmental impact, they may need to include “balancing information” where omitting it could otherwise mislead consumers about the initiative’s significance, relative to the company’s overall activities. Businesses in higher-emitting sectors, such as fossil fuel companies and those who finance the industry, need to be particularly careful in this respect.

So, ads with claims about such initiatives, activities or investments may need to include information explaining how the initiative compares to the business’s other, more harmful activities. For example, clarifying the size or scale of the initiative in proportion to total operations, or the environmental impact it has compared with the company’s wider footprint​.

The extent and prominence of balancing information needed will depend on the context and narrative of the ad. If the ad already shows or refers to the business’s high‑impact activities, a less prominent qualification may be acceptable. If these activities are not acknowledged in the main narrative, then small‑print or low‑prominence balancing information may not be adequate.

In 2025, the ASA investigated a TV ad for Shell that featured  a person walking through a number of different scenes relating to Shell’s activities, including installation of EV chargers, gas extraction on an offshore rig, gas being used in a kitchen, a miniature windfarm and a group of engineers welding metal. The main creative strands of the ad were supported by superimposed text which stated that, as a proportion of Shell’s global capital investment in 2023, 68% was directed to oil & gas, 23% to low-carbon energy solutions and 9% to other non-energy products.

The ASA considered the ad did not focus singularly on the environmentally beneficial initiatives, and made sufficiently clear that Shell was involved in both higher and lower-carbon activities. Through qualifying information, it also made clear that the majority of Shell’s investments comprised oil and gas, and to what degree. The ruling concluded the ad had not given a misleading overall impression of Shell’s environmental impactand was not upheld. (Shell UK Ltd, 9 April 2025).

In 2023, the ASA ruled against a national press ad for energy company Equinor. The ad stated “Wind, oil, gas, carbon capture […]” and “IT’S ALL PART OF THE BROADER ENERGY PICTURE”, and “we’re producing the oil and gas the UK needs now; and will be powering millions more homes with wind, capturing and storing carbon safely […]. It’s broad energy for a brighter future”. Whilst the ruling noted the ad was clear that the UK energy blend was in transition, the ASA considered it gave the overall impression that carbon capture and storage (CCS) and energy from windfarms formed a significant proportion of Equinor’s business activities, alongside oil and gas. However, the ASA understood that large-scale global oil and gas investment and extraction formed the vast majority of Equinor’s business activities, and would continue to do so in the near future.

The ASA considered that further information about the overall proportion of Equinor’s business model that comprised renewable energy and CCS was material information that should have been included. As the ad omitted that significant information, the ruling concluded it was likely to mislead. (Equinor ASA, 20 December 2023).

Natural world imagery

Imagery in ads associated with nature or the use of the colour green, can influence how consumers are likely to interpret environmental claims.

In 2024, ads for Lloyds Bank included imagery of an electric car, powered by renewable electricity, driving in a suburban setting before entering a rural area. A final scene showed imagery of planet Earth with the text “Helping Britain Prosper”, the word “Prosper” in green. The ad also made various claims about the marketer’s investment in cleaner energy, including that Lloyds was putting the “weight of [its] finance” into renewable energy. The ASA considered those claims and the imagery in the ad, in the absence of qualifying, balancing information, gave the misleading impression that renewable energy formed a significant proportion of Lloyds’ investments and the companies it financed. (Lloyds Bank plc, 18 December 2024). 

The ASA also investigated ads for fruit drinks showing animated characters singing “We’re messing up the planet […]”, alongside imagery of expelled pollutants, litter, and dirty rivers. As the song changed to “Let’s get fixing up the planet. Fix it up real good…” a voiceover said “Reduce. Re-use. Recycle. […] If we’re looking after nature she’ll be looking after me…Innocent. Little drinks with big dreams for a healthier planet”.  The animation then changed to a greener colour scheme, showed trees being planted and fruit being squeezed into a bottle.

The ASA accepted that some consumers might understand the claims as suggesting that the advertiser had made an aspirational commitment to do better for the environment. However, it also considered the claims could be understood to be suggesting that purchasing the advertiser’s products would result in environmental benefits. The advertiser was able to demonstrate that they had taken action to reduce the environmental impact of their business and products, but could not show that their products had a net positive environmental impact over their full lifecycles, so the ads were found to be misleading. (Innocent Ltd, 23 February 2022).

Further guidance can be found in Key Advice Resources on Green Claims, and in other ‘environmental’ AdviceOnline entries in the Resource Library, including:

More on