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 Calvin Klein, a fashion retailer, seen on 9 December 2025 stated "Calvin Klein tops for women. Responsibly sourced collections – Recycled, Organic & More”.
Issue
The ASA challenged whether the claim “Responsibly sourced collections – Recycled, Organic & More” was misleading and could be substantiated.
Response
Calvin Klein Europe B.V. t/a Calvin Klein said the ad promoted Calvin Klein’s women’s tops and linked to a landing page which housed its range of women’s T-shirts and tops. They believed that consumers would understand the claim as meaning that certain collections from within the women’s tops range included environmentally preferred materials, including recycled, organic, and other materials. They said it would not be reasonable for consumers to interpret the ad as meaning that all products in the women’s tops range contained, in whole or part, recycled, organic, or other environmentally preferred materials.
Due to the reference to “collections”, in their view, consumers would understand that Calvin Klein’s women’s tops range comprised various styles, some of which might be made of a combination of environmentally preferred materials, including recycled and organic fibres which were two examples. The “& More” signalled the presence of other environmentally preferred materials, such as those with third-party certification.
Calvin Klein said that text on the landing page reinforced the ad’s message. Text towards the bottom of the page outlined that “The Calvin Klein collection includes recycled materials and organic cotton so you can make a conscious fashion choice”. They also stated that individual product pages set out the fabric composition of each style in the women’s tops range.
Calvin Klein said that, at the date of the ad, a significant proportion of the distinct styles within the women’s tops range incorporated some form of third-party certified material, namely a recycled, organic and/or otherwise certified material. Of those, the certified material content per style ranged from 20% to 100% with most of the styles being at the upper end of that range.
They explained that their environmentally preferred material sourcing strategy was informed by third-party verified environmental impact data and internationally recognised certifications administered by third-party bodies.
Calvin Klein acknowledged that the claim, as presented in the constrained format of a paid-for Google search ad, had not included the level of detail that would most precisely have communicated its scope. However, they did not believe that the ad was misleading. They said that they had taken immediate steps to remove the ad and were committed to ensuring all future environmental claims and claims related to the fabric composition of their clothes were clearly qualified.
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 is 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 "Calvin Klein tops for women. Responsibly sourced collections - Recycled, Organic, & More". We considered that consumers would understand the claim to mean that Calvin Klein sold women’s tops, some of which were part of “Responsibly sourced” collections, due to them being made from recycled, organic or other environmentally preferred materials. However, we considered that the extent to which recycled, organic or other environmentally preferred materials were used in each product in those collections was unclear. We therefore considered consumers would interpret the claim, without further clarification, as meaning the tops within those collections were entirely made from recycled, organic or other environmentally preferred materials.
We considered that the basis of the fabric composition claim was unclear. We considered that information was material and likely to affect consumers’ understanding of the ad’s overall message. We noted that the ad’s landing page, one click away, stated towards the bottom of the page “[...] The Calvin Klein collection includes recycled materials and organic cotton so you can make a conscious fashion choice [...]". Consumers would only have been aware of that statement if they read the full page of text on the landing page, which was not necessary to do in order to proceed with a purchase. In any event, we considered that statement did not clarify the extent to which the tops were comprised of recycled, organic or other environmentally preferred materials to enable consumers to proceed on their consumer journey in an informed manner. We considered that the ad was not limited by time or space to such an extent that the information could not have been provided.
We considered that the references to the types of materials used in the “Responsibly sourced” collections were absolute claims. We therefore expected to see evidence that the tops in those collections were made entirely from recycled, organic or other environmentally preferred materials.
We reviewed the evidence that Calvin Klein had provided. We acknowledged that for most of their women’s tops which contained recycled, organic or other certified fabrics, those materials made up the majority of the total fabric content. We also acknowledged that some products were entirely made from organic material or other certified fabrics that constituted the “& More” collections referred to in the ad. However, there were no tops that were entirely made from recycled material, and not all the tops made with organic or other certified fabrics were entirely made from them. For those reasons, we considered the ad’s claim had not been adequately substantiated.
The basis of the claim “Responsibly sourced collections – Recycled, Organic & More” had not been made clear and we had not seen evidence to support it as consumers were likely to understand it. We therefore concluded that 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 Calvin Klein Europe B.V. t/a Calvin Klein to ensure that their future ads made the basis of any environmental claims clear and did not suggest that their products were made entirely from recycled, organic or other environmentally preferred materials when that was not the case.
