Ad description

A paid-for Facebook ad for Charles Tyrwhitt, a clothing retailer, seen on 28 July 2023, featured an image of a print cotton shirt. Text on the post stated “[…] We’re proud to be a Carbon Neutral business”.


The ASA challenged whether the ad was misleading because it failed to make the basis of the claim “Carbon Neutral business” clear.


Charles Tyrwhitt Shirts said that all claims they made about their carbon neutrality were factually correct. They said these claims were based on a report, achieved through a partnership with the sustainability consultancy Planet Mark and under the guidelines of PAS2060, the specification published by the British Standards Institution detailing how companies should demonstrate their carbon neutrality.



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 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 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 considered that consumers would understand from the ad that Charles Tyrwhitt Shirts was a carbon neutral company, meaning that, as a business, they balanced the amount of carbon emitted into the atmosphere by an equivalent amount removed. Within that context, we considered consumers would understand that purchasing a Charles Tyrwhitt Shirts product would have a net neutral impact on carbon emissions and, therefore, climate change.

However, we considered there was no information in the ad which explained the basis for Charles Tyrwhitt Shirts’ claim that they were a “carbon neutral business”. Although we acknowledged that Charles Tyrwhitt Shirts had based their claim on a report by a sustainability consultancy which they said demonstrated their carbon neutrality, we considered that they had not provided any qualifying information within the ad for the basis of the “carbon neutral” claim.

Because there was no qualifying information in the ad which outlined the basis for the “carbon neutral” claim, which we considered was significant information that consumers needed to know in order to fully understand the claim’s meaning, we concluded that the ad was misleading.

The ad breached CAP Code (Edition 12) rule 3.1, 3.3 (Misleading advertising) and 11.1 (Environmental claims).


The ad must not appear again in the form complained about. We told Charles Tyrwhitt Shirts Ltd to ensure that the basis of future environmental claims were clear.


11.1     3.3     3.1    

CAP Code (Edition 12)

11.1     3.3     3.1    

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