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.
Ad description
A website, www.cruise1st.co.uk, for cruise 1st seen on 15 April 2025, included a page dedicated to MSC Cruise’s offerings which made the claims “Powered by LNG, the world’s cleanest marine fuel”, “Uses new green technologies”, “If you’re keen on cruising but worried about the environmental impact, the MSC World Europa offers a green alternative. With sustainability and lessening the impact of cruises on marine life a key driver in the ship’s design, you can rest easy knowing you’re being powered by cleaner fuel and being propelled by blades that mitigate the worst impacts of underwater noise”.
Issue
The ASA challenged whether the ad gave a misleading impression of the environmental impact of the advertised cruise ship.
Response
Sunshine Cruise Holidays Ltd t/a cruise 1st said they were an agency and acted as a representative platform for cruise lines. The content of the ad had been populated directly from the featured cruise line’s official sources. They said the ad referred to how the featured cruise ship was using liquefied natural gas (LNG) – a form of marine fuel – was more environmentally friendly than traditional marine fuels. They explained that MSC Cruises had made considerable investment in LNG and exploring renewable alternative marine fuels such as bio-LNG and synthetic LNG. Following contact from the ASA they had updated the ad.
MSC Cruise S.A. t/a MSC Cruises said they had no control over the form of wording used by travel agents in, among other places, their advertising. The wording in the challenged claims had not been supplied to cruise 1st and had not at any time appeared in MSC Cruises’ own promotional materials.
Assessment
Upheld
The CAP Code required that the basis of environmental claims, and comparative claims must be clear. It stated that unqualified claims could mislead if they omitted material information, absolute claims must be supported by a high level of substantiation and that marketing communications must not mislead consumers by exaggerating the capability or performance of a product.
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.
The ASA considered the overall impression of the ad, which claimed MSC World Europa cruise ship offered a “green alternative”, was that by choosing to travel on the relevant ship over those operated by other cruise companies, consumers would lessen their impact on marine life, and the environment more generally. They would understand from the ad that lower impact was achieved, in part, through the use of “green technologies”, and LNG, which the ad claimed was the cleanest marine fuel available globally. The ad referred to consumers’ worries about the environmental impact of cruising and sought to reassure them in that regard.
The claims, “LNG the world’s cleanest marine fuel”, “Uses new green technologies”, “the MSC World Europa offers a green alternative” were absolute claims, pertaining to the performance of the fuel, the technologies used by the ship and the environmental impact of the ship as a whole in comparison with other cruise providers. However, evidence to support the claims had not been provided.
We assessed the claims as they related to fuel. LNG was a fossil fuel that primarily comprised methane and produced lower levels of carbon dioxide (CO2) and other greenhouse gas (GHG) emissions, such as sulphur oxide and nitrogen oxide, than traditional marine fuel when burned. However, its production and use had other potentially negative environmental impacts, such as methane slip and leakage, which was the emission of unburned methane into the atmosphere, at all stages of the fuel’s life cycle from production through to burning. We understood methane emissions were making a substantial contribution to climate change. We further understood LNG produced reduced, but still significant, CO2 emissions over its full life cycle, which was not explained in the ad. Therefore, while the environmental impact of LNG might have been lower than that of traditional fuel types, it was not without impact and the ad had not given information to put the impact of the fuel into context.
We next assessed the claims related to wider environmental impact. We understood the cruise ship used a type of propellor that reduced the impact of noise on marine life. However, we understood cruising’s impact went beyond underwater noise, and that MSC Cruises’ ships engaged in 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. However, the ad had not provided further detail to explain the role and impact of other “green technologies” beyond the use of modern blades to minimise underwater noise.
The ad claimed that consumers could “rest easy” knowing they were cruising on a ship powered by the cleanest fuel and a modern blade type. However, it had not provided enough information to contextualise those claims. In addition, evidence to support the claim to offer a “green alternative” had not been sufficiently substantiated.
For those reasons concluded the ad had exaggerated the environmental credentials of the advertised cruise ship and as a result the ad was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), 3.7 (Substantiation), 3.11 (Exaggeration), 3.32 (Comparisons with identifiable competitors), 11.1, 11.2, and 11.3 (Environmental claims).
Action
The ad must not appear again in the form complained of. We told Sunshine Cruise Holidays Ltd t/a cruise 1st to ensure the basis of future environmental claims, and comparative claims, was made clear, and that appropriate evidence was held to support them to ensure that such claims were not exaggerated. We also told them to ensure they included all material information about the environmental impact of cruises they sold, where the omission of that information was likely to mislead.
CAP Code (Edition 12)
3.1 3.3 3.7 3.11 3.32 11.1 11.2 11.3
