Background
This ruling forms part of a wider piece of work on environmental claims. These ads were identified for investigation following a complaint received, and intelligence gathering by our Active Ad Monitoring system. See also related rulings published on 3 September
On 7 April 2025, the Advertising Codes were updated to reflect the revocation and restatement of the Consumer Protection from Unfair Trading Regulations 2008 (CPRs – the legislation from which the majority of the CAP and BCAP rules on misleading advertising derived) by the Unfair Commercial Practices provisions in the Digital Markets, Competition and Consumers Act 2024 (DMCCA). On that date, the wording of a number of the rules in the Advertising Codes was changed to reflect relevant changes introduced by the DMCCA on 6 April 2025.
Given that the complaint that formed the subject of this ruling was received before 7 April 2025, the ASA considered the ads and complaints under the wording of the rules that existed prior to 7 April 2025, and the Ruling (and references to rules within it) should therefore be read in line with this wording, available here – CAP Code and BCAP Code.
Ad description
A paid-for Google ad for travel agency BarrheadTravel, seen on 29 March 2025, stated “Celebrity Cruises. A Strong Focus On Sustainability And Eco-friendly Practices”.
Issue
The ASA challenged whether the ad gave a misleading impression of the advertised cruises’ environmental impact.
Response
Barrhead Travel Service Ltd t/a BarrheadTravel said the wording used in the ad was taken, in part, from the cruise supplier’s website. The words “Strong Focus” did not appear on the supplier’s website and had been added by Barrhead Travel in the copy submitted to their digital agency. While they were aware of the measures the supplier had in place in relation to the claimed practices , they acknowledged that would not have been apparent to consumers from the content of the ad. Following contact from the ASA they had removed the ad.
RCL Cruises Ltd t/a Celebrity Cruises said they had not been involved in the creation, approval, or publication of the ad.
Assessment
Upheld
The CAP Code required that the basis of environmental claims must be clear, and that absolute environmental claims must be supported by a high level of substantiation.
The ASA considered consumers would interpret the claim “A Strong Focus On Sustainability And Eco-friendly Practices”, as meaning Celebrity Cruises had sustainability and “eco-friendly” practices at the heart of the cruises they operated.
Many consumers were increasingly concerned about the environmental impact of activities related to higher-carbon products and services, such as cruising. They would be interested in seeking out cruise operators that were making a meaningful effort to reduce their environmental impact. We therefore considered the ad would appeal to consumers who had concerns about the environmental impacts of cruising, and offered them reassurance about the cruises operated by Celebrity Cruises.
The ad did not make clear the basis or meaning of the claim “A Strong Focus On Sustainability And Eco-friendly Practices” and Barrhead Travel did not supply evidence to demonstrate that sustainability or “eco-friendly” practices were at the heart of Celebrity Cruise’s operations. However, we understood cruise ships that used conventional marine fuel produced high levels of both carbon dioxide (CO2) and non-CO2 emissions, which were making a substantial contribution to climate change. We further understood Celebrity Cruises had an environmental impact that went beyond greenhouse gas (GHG) emissions and included the discharge of greywater (from sinks, showers, laundry facilities, and kitchens), blackwater (sewage), ballast water, and water from exhaust gas cleaning systems that removed some GHGs from ships’ exhaust stacks, all of which could harm marine life and ecosystems.
The ad did not explain the basis of the claim “A Strong Focus On Sustainability And Eco-friendly Practices” and we had not seen evidence to demonstrate that sustainability or “eco-friendly” practices were at the heart of Celebrity Cruise’s operations. We therefore concluded it was likely to mislead. We welcomed BarrheadTravel’s decision to remove it.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 11.1 and 11.3 (Environmental claims).
Action
The ad must not appear again in the form investigated. We told Barrhead Travel Service Ltd t/a BarrheadTravel to ensure that the basis of future environmental claims was made clear and that robust substantiation was held to support them.
