Background
This ruling forms part of a wider piece of work on ads making carbon neutral delivery or similar claims. The ads were identified for investigation through both intelligence gathered by the ASA and the use of the Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules. See also related rulings published on 11 November 2026.
Ad description
A paid-for Google search ad, for SportsShoes.com, seen on 9 June 2026 stated "Over 12,000 products on site from a wide range of brands [...] Carbon Neutral Deliveries [...]".
Issue
The ASA challenged whether the ad made the basis of the claim “Carbon Neutral Deliveries” clear.
Response
B Sporting Ltd t/a SportsShoes.com said the claim "Carbon Neutral Deliveries" was intended to communicate that the carbon emissions associated with delivering customers' orders, from their warehouse to the customer's address, were measured and offset so that the net carbon impact of the delivery was neutralised. The claim was not intended to imply that the deliveries produced no greenhouse gas (ghg) emissions, nor that the products themselves, over the course of their entire life cycle, were carbon neutral. They said that they had engaged a third-party environmental and business consultancy to conduct two ghg emissions assessments to understand better their environmental impact and to inform their decarbonisation strategy. Based off the estimated emissions assessed through that work, they invested in a carbon sequestration project to offset an equivalent amount of carbon emissions to their Scope 1, 2, and 3 emissions.
With search ads being of limited space, the intention was that consumers would understand that supporting information explaining the basis of the ad's claim could be found on their website. They explained that the ad’s landing page was variable, and could be adjusted to their home page, a product listing page, or a product detail page. The page on their website explaining the claim had been deleted, and they said they were subsequently reviewing its reinstatement and presentation. They said the search ad had been removed as part of routine housekeeping and was no longer in use. In the future relevant ads would be sent to their environmental and business consultancy for approval prior to publication.
Assessment
Upheld
The CAP Code required that the basis of environmental claims must be clear and stated that unqualified claims could mislead if material information was omitted. CAP Guidance on “Misleading environmental claims and social responsibility in advertising” stated that advertisers should avoid using unqualified carbon neutral claims, and because information explaining the basis for those claims helped consumers’ understanding, such information should therefore not be omitted. It further stated that accurate information about whether (and the degree to which) the claim was based on an active reduction of carbon emissions or based on offsetting should be included in ads to ensure consumers understood the basis on which carbon neutrality was achieved. The ASA assessed the ad in question against the CAP Code, having regard to the CAP Guidance.
We accepted SpotsShoes.com’s view that the claim “Carbon Neutral Deliveries” would be understood as meaning that the delivery only, rather than full life cycle of their products, was “Carbon Neutral”. We considered the claim, as it was presented in the ad, would be understood by consumers as meaning that steps had been taken to ensure that the delivery of those products did not result in a net increase in the amount of carbon being released into the atmosphere, but, from the ad, it was ambiguous if that was achieved via offsetting credits or via the actual removal of any sources of emissions.
We understood the claim depended on the use of offsetting credits. However, there was no information in the ad that made that clear, which we considered was necessary to explain how the carbon neutral status was achieved, including by outlining whether, and the degree to which, the claim depended on an active reduction of carbon emissions or if it was based on the use of offsetting credits. While the ad was short-form and subject to space limitations, it had a limit of 270 characters, it was, therefore, not so limited that SportsShoes.com could not have made the basis of the claim clear so that consumers could proceed with their consumer journey in an informed manner. In addition, the ad’s landing page did not include information that explained the basis of the claim.
We welcomed that SportsShoes.com were taking further due diligence before publishing ads with environmental claims. However, as the ad had omitted material information that explained the basis of the “Carbon Neutral Deliveries” claim, we concluded it was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising) and 11.1 (Environmental claims).
Action
The ad must not appear again in the form investigated. We reminded B Sporting Ltd t/a SportsShoes.com to ensure that they made the basis of all environmental claims clear, including in relation to what extent any “Carbon Neutral Deliveries” claims depended on the use of offsetting credits or the actual removal of any source of emissions.
