A poster, seen on the London Underground on 7 November 2022, for Intrepid Travel. The ad featured two women in front of the Giza Pyramids in Egypt, alongside the text “People & planet-friendly small group adventures since 1989”.
The complainant challenged whether the claim “people & planet-friendly small group adventures” misleadingly minimised the impact of Intrepid Travel’s holidays on the environment.
Intrepid Travel Group UK Ltd considered that the average reader of the ad would interpret “people & planet-friendly small group adventures since 1989” as a limited claim related to their small group tour offerings, rather than an absolute environmental claim which included travel to and from the destination country. They further highlighted that the claim sufficiently conveyed the limits of the life cycle through the use of “small group adventures since 1989”. They asserted that made it clear the claim was a narrow and direct reference to their small group tours and that the inclusion of the Giza pyramids, alongside two travellers, further implied that the ad was a reference to their Egypt tour. Accordingly, they considered the ad had not misrepresented the impact of international flights or their tours on the environment.
Intrepid Travel also highlighted that the ad included a link to their website which could be accessed by consumers and contained qualifying information regarding their environmental credentials. They considered that information was accessible and transparent, which allowed consumers to make an informed purchasing decision. They stated that they were certified as carbon neutral by Climate Active for their business operations and services. They explained that to achieve that certification, all greenhouse gas emissions attributable to an Intrepid tour throughout its life cycle were measured and offset through carbon credits that they purchased. They detailed that greenhouse gas emissions which were measured comprised of tour marketing and advertising, booking and payment systems, tour information materials, tour transport (air, water, public and land), tour accommodation, tour activities, tour waste and tour meals. They also supplied a section from their website which detailed carbon offset projects they supported through the scheme. They re-iterated that they offset their annual emissions footprint in its entirety and that they had been carbon neutral since 2010.
Intrepid Travel also provided details of a number of schemes which they considered substantiated their positive impact on the environment. These they felt were reflective of their daily business operations, such as their Seven Point Commitment Plan and Science Based Targets Initiative (SBTi) membership to reduce greenhouse gas emissions.
The CAP Code stated that the basis of environmental claims must be clear, and that unqualified claims could mislead if they omitted significant information. It also stated that claims must be based on the full life cycle of the advertised product, unless the ad stated otherwise, and required that marketing communications did not mislead consumers about a product’s total environmental impact. The Code further required that absolute claims were supported by a high level of substantiation.
The ad featured the claim “people & planet-friendly small group adventures since 1989”. We noted Intrepid Travel’s comments that they did not offer flights as part of their travel packages and that consumers would therefore understand that the claim was a narrow reference to their tour offering only. However, we considered that the claim was not qualified with that information. We considered that the presentation of the Giza Pyramids in Egypt within the ad, together with the claim “planet-friendly”, indicated that such tours were international and that it would be necessary to travel, in most cases by flying, to take part in their tours. We considered that this impression was further reinforced by the claim not referring specifically to the tours offered by Intrepid Travel, and considered that, in the absence of qualifying information, “adventures” was likely to be interpreted by consumers as referring to holidays as a whole, which would include flights to and from the destination country.
We considered that the claim “people & planet-friendly small group adventures” was an absolute claim, which would be understood to mean that taking part in an Intrepid tour caused no environmental damage throughout its full life cycle. We therefore expected to see evidence which demonstrated that taking part in an Intrepid Travel tour, including the necessary travel to and from the destination location, caused no environmental damage over its full life cycle.
We assessed the evidence provided by Intrepid Travel. Whilst we acknowledged that they took part in a number of environmental schemes alongside their carbon offsetting programme, we considered that those schemes did not specifically relate to the life cycle of a holiday with Intrepid Travel, and they had not been referred to in the ad. We looked at the initiatives and targets Intrepid said they were committed to delivering, for example the Seven Point Commitment Plan and their SBTi membership, but noted that many of those initiatives were targeted to deliver results years into the future. We therefore considered that they did not relate to the claim as it would be interpreted by consumers.
We understood that Intrepid Travel were certified as carbon neutral regarding their business operations because they offset the carbon emissions generated during their tours, such as emissions related to accommodation, meals and transfers, by purchasing carbon credits. In any case, we understood that Intrepid Travel did not calculate all greenhouses gases produced by their consumers travelling to and from their tour locations, nor did their offsetting programme take account of those emissions. We therefore considered that their carbon offsetting did not take account of all emissions attributable to the way in which consumers would likely interpret the claim “planet-friendly adventures”. Because air travel produced high levels of both CO2 and non-CO2 emissions, which made a substantial contribution to climate change, and those emissions were not accounted for by Intrepid Travel, we considered that the absolute claim “people & planet-friendly adventures” had not been adequately substantiated.
Because the basis of the claim had not been made clear and we had not seen evidence based on the full life cycle of the product to support the absolute claim “people & planet-friendly small group adventures” as it would be understood by consumers, we concluded the ad had misleadingly minimised the impact of Intrepid Travel’s holidays.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), and 11.1, 11.3 and 11.4 (Environmental claims).
The ad must not appear again in the form complained of. We told Intrepid Travel Group UK Ltd to ensure that the basis of future environmental claims was made clear and did not give a misleading impression of the impact of their holidays and that robust substantiation was held to support them.