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 3 December 2025.
Ad description
A paid-for Google ad for Superdry, a clothing retailer, seen on 30 June 2025, stated “Superdry: Sustainable Style. Unlock a wardrobe that combines style and sustainability […]”.
Issue
The ASA challenged whether the claim “Sustainable style. Unlock a wardrobe that combines style and sustainability” was misleading.
Response
Supergroup Internet Ltd t/a Superdry said the purpose of the ad was to highlight that they manufactured, sourced and sold products across a range of category types that had sustainability attributes and credentials which a consumer might purchase to form a ‘wardrobe’ or collection of clothes. They said consumers would understand the ad to mean the products within the collection were either stylish, had sustainable attributes and credentials, or both. In their view the ad did not make an absolute claim, nor did it suggest all Superdry products were sustainable.
Superdry explained the ad was a Google Performance Max advert meaning it was an automated, goal-based ad within Google Ads. That meant the way in which the consumer populated their Google search determined where on the Superdry website they landed after clicking on the ad. As such, the consumer journey would not be the same for all consumers. They said that, where applicable, the sustainability attributes and credentials for a product were clearly available on the relevant product page on the website, for which they held appropriate substantiation.
Superdry assessed their raw materials and products against sustainability standards, resource materials and certifications produced by the Textile Exchange, an independent body. Products would only be determined to have sustainability attributes and credentials if they met those standards and a technical certificate was issued. They provided examples of product listings on the Superdry website to which the ad might have linked and the associated independent transaction certificates which, in their view, supported the sustainability claim in the ad. Each of the product listings contained information about the product’s fabric composition, such as “recycled lining and padding”; “100% organic cotton”; “over 50% cotton in conversion”, together with a short description of what this meant. The associated transaction certificate provided set out the standard to which the product adhered and certified the product’s fabric composition.
Superdry said they determined a product’s sustainability based on a three-pillar approach as set out in their FY24 Sustainability Report: being lower impact on the environment (through use of low impact materials); moving towards net zero; and communicating with integrity. In terms of the first pillar, the FY24 Sustainability Report specified that 64% of all garments, footwear and accessories bought contained a sustainably sourced material. They provided a copy of their FY24 Full Product Order Book which contained quantities, material composition and product categories for FY24 in support of that percentage, which was calculated by taking the total volume of garments and then excluding any garments that did not have sustainability credentials in line with the Textile Exchange standards. The FY24 Full Product Order Book also showed that 40% of all of the raw materials that were sourced to produce Superdry products contain recycled and ‘low impact’ alternatives to conventional polyester, nylon, modal and viscose fibres and that, where possible, organic and in conversion cotton was sourced instead of conventional cotton.
Superdry acknowledged that, on reviewing the ad, the full life cycle of their products was not publicly available and, as such, the ad had been produced in error. They gave assurances that the ad had been removed and would not be used again. Notwithstanding that, they did not consider the ad had resulted in consumers being misled about the sustainability attributes and credentials of their products.
Assessment
Upheld
The CAP Code required that the basis of environmental claims must be clear, the meaning of all terms must be clear, and that absolute environmental claims must be supported by a high level of substantiation. Claims must be based on the full life cycle of the advertised product, unless the ad stated otherwise.
The Competition and Markets Authority guidance ‘Complying with consumer law when making environmental claims in the fashion retail sector’ (the CMA Guidance) stated that broader, general or absolute claims such as “sustainable” were likely to mislead consumers, and that their meaning was unclear. It further stated that consumers were likely to assume from the use of the term that the product about which it was used as a whole had a positive environmental impact, or at least no adverse impact. The ASA had regard to the guidance in assessing whether the ad had complied with the CAP Code.
The ad stated, “Sustainable Style. Unlock a wardrobe that combines style and sustainability” and did not include qualifying information explaining the basis of the terms “sustainable” and “sustainability”. We considered that without qualification the "sustainable" claim was ambiguous and unclear. The claim was absolute and therefore a high level of substantiation in support needed to be produced.
While ambiguous, we considered the term “sustainable”, in the context of the ad, was likely to be understood as meaning that all Superdry clothes, shoes and accessories, across their entire life cycle, would at the very least have no detrimental impact on the environment. We understood that 64% of all Superdry garments, footwear and accessories bought in 2024 contained sustainably sourced materials. Additionally, Superdry had not provided evidence to demonstrate that their products had no detrimental effect on the environment, taking into account their entire life cycle.
The basis of the claim “Sustainable Style. Unlock a wardrobe that combines style and sustainability” had not been made clear, its meaning was unlikely to be understood, and we had not seen evidence to support it. We therefore concluded the ad was likely to mislead. We welcomed Superdry’s decision to remove the ad.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation), 11.1, 11.2, 11.3 and 11.4 (Environmental claims).
Action
The ad must not appear again in the form investigated. We told Supergroup Internet Ltd t/a Superdry to ensure that the basis of future environmental claims, and their meaning, was made clear, and that a high level of substantiation must be held to support absolute claims.
