Background
This Ruling forms part of a wider piece of work investigating environmental claims in the retail fashion sector. The ads were identified for investigation following intelligence gathering by our Active Ad Monitoring system which uses AI to proactively survey ads in specific sectors. See also related rulings published on 24 June 2025.
Ad description
A paid-for Google ad for adidas, a fashion retailer, seen on 18 December 2025, stated “adidas Recycled Running Shoes […] Check Out Our Recycled Shoe Range Today”.
Issue
The ASA challenged whether the claim “Recycled Running Shoes” was misleading and could be substantiated.
Response
Adidas UK Ltd t/a adidas said consumers would interpret the claim "Recycled Running Shoes" as meaning their running shoes contained materials derived from recycled sources. They explained they did not a operate a standalone recycled running shoe range. Instead, certain products across their collections might incorporate recycled materials – the extent to which recycled content was used varied by product and material type.
They said the adidas website did not contain pages dedicated to ‘recycled running shoes’ or ‘recycled shoes’. While they were not able to identify the webpage the ad linked to, they did however explain that a search engine query for ‘adidas recycled running shoes’ took consumers to a webpage which featured running shoes, some of which contained some recycled materials. Once a consumer clicked on an image of a product on that page, they could navigate to a drop-down "Details" section which included precise information on the recycled content of the product, if any.
Adidas said that all recycled content claims were substantiated through internal product documentation and material verification processes which enabled them to confirm, prior to making any recycled content claims, whether a product contained recycled materials and whether the underlying documentation supported that claim. Any reference to recycled content in their product descriptions aligned with that process.
Assessment
Upheld
The CAP Code required that the basis of environmental claims must be clear and stated that unqualified claims could mislead if they omitted material information. It also required that absolute environmental claims must be supported by a high level of substantiation.
The Competition and Markets Authority guidance ‘Complying with consumer law when making environmental claims in the fashion retail sector’ (the CMA Guidance) stated that advertisers should not imply that a product was entirely made of a single fabric if that was not true. A product should not be described as, for example, “recycled” or “organic” if it contained fibres that were not recycled or organic, unless the proportion of non-recycled or non-organic fibres was negligible. The ASA had regard to the guidance in assessing whether the ad had complied with the CAP Code.
The ad stated “adidas Recycled Running Shoes […] Check Out Our Recycled Shoe Range Today”. As the ad did not include information explaining the basis of the claim “Recycled Running Shoes”, we considered the meaning of the claim was unclear. We considered that in the context of the ad and given the reference within it to a “Range”, the claim “Recycled Running Shoes” was likely to be understood as meaning that all shoes in their recycled running shoe range were made from 100% recycled materials.
The claim was absolute and, therefore, we expected to see evidence showing that all shoes in a recycled running shoe range were made entirely from recycled materials. As adidas did not have a specific recycled running shoe range, we instead applied that evidential standard to their running shoes that contained recycled material. However, adidas did not provide evidence that showed that all those running shoes were made from 100% recycled material.
The basis of the claim “Recycled Running Shoes” had not been made clear and we had not seen evidence to support it as consumers were likely to understand it. We therefore concluded the ad was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), 3.7 (Substantiation), 11.1 and 11.3 (Environmental claims).
Action
The ad must not appear again in the form investigated. We told Adidas UK Ltd t/a adidas to ensure that their future ads made the basis of any environmental claims clear and did not suggest their running shoes or other products were entirely made from recycled materials when that was not the case, and that a high level of substantiation must be held to support absolute claims.
