A fundamental principle of our environmental rules, is that “unqualified claims could mislead if they omit material information” (rule 11.1). Although ads may often describe green initiatives, which might for instance lead to reductions in emissions, ads for companies operating in higher carbon sectors that focus only on their more environmentally beneficial work, without providing more context about the wider framework of a brand’s overall environmental impact, are likely to breach this rule.
The ASA recently published some key rulings on this topic – let’s take a look at two of them in more detail.
TotalEnergies – Upheld
A complaint about a social media ad by TotalEnergies was ruled against for omitting information about their environment impact. The ad focused entirely on an example from the business’s electricity start-up accelerator programme and the support they had offered to a company that designed wind and solar farms. The ad clicked through to the TotalEnergies website, where more information was provided.
The ASA considered that the social media ad framed the programme and support as representative of the advertiser’s overall balance of work. However, a significant proportion of the energy products produced and sold by the advertiser were from fossil-fuels. More information was provided on the TotalEnergies’ website, but not on the page accessed directly via the click through.
Because the social media ad did not include information to balance out the message, it was considered misleading by omission, and the complaint was upheld on that basis.
Shell UK – Not Upheld
In contrast, the ASA did not uphold complaints that a TV ad for energy company Shell gave a misleading impression of their environmental impact.
The ad’s main creative included visuals and a voice-over that referred to Shell’s provision of energy to the UK. It showed several functions including the installation of electric vehicle chargers and the delivery of energy into a home and highlighted the role it played in building skills for the energy transition. The ad featured imagery of a model windfarm and an offshore gas rig. Superimposed text set out the proportions of Shell’s Capital Expenditure that comprised oil and gas and lower-carbon initiatives.
The ASA concluded that the ad – across the visual, voice-over, and superimposed text – had provided a balanced picture of Shell’s overall business. They also considered that viewers would understand from the ad that Shell was active in both higher and lower carbon activity and through qualifying information that the majority of Shell’s investments comprised oil and gas, and to what degree. As such, the complaints were not upheld.
Need advice?
For further support, we offer an eLearning module and several free online resources. You can also seek bespoke advice on your own non-broadcast advertising from the Copy Advice team.
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