Background
This Ruling forms part of a wider piece of work on environmental claims in the travel agent sector. This ad was identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules. See also related rulings published on 9 September 2026.
Ad description
A paid-for Google ad for Thomas Cook, seen on 15 July 2026, stated “Sandos Caracol Eco Resort”. Text underneath stated “Relax at Sandos Caracol Eco Resort – flights included. Book now with Thomas Cook”. Alongside that was an image of two people in a swimming pool.
Issue
The ASA challenged whether the basis of the claim “Eco Resort” was clear.
Response
Thomas Cook Tourism (UK) Company Ltd t/a Thomas Cook said that in creating the ad they had used either the Google Ads tools Performance Max or Dynamic Search Ads. Those tools automatically generated parts of search ads based on the terms used by consumers when searching with the engine. They said the phrase “Eco Resort” therefore appeared automatically in the ad, in response to user search terms.
They said the hotel changed its name in July 2025. However, given some consumers knew the hotel by its previous name, they may have used it when searching for the hotel. Upon receipt of the ASA’s correspondence, Thomas Cook had taken steps to block “Sandos Caracol Eco” as a search keyword term to prevent it appearing in future searches.
Assessment
Upheld
The CAP Code required that the basis of environmental claims must be clear. Unqualified claims could mislead if they omitted material information.
The ASA considered consumers would interpret the claim “Eco Resort” in the ad as meaning the advertised accommodation had some environmental characteristics or benefits. While the claim was part of the accommodation’s name, we considered it would also be understood as a description of the resort.
The term “eco” did not have a standardised meaning. Its basis when used as shorthand to describe the environmental characteristics or benefits of accommodation was therefore likely to differ between accommodation providers. Accordingly, consumers needed sufficient information about the basis of such a claim to understand what environmental characteristics or benefits were being referred to. That information would enable them to assess the relevance and significance of those characteristics when deciding whether or not to proceed on their consumer journey.
We understood from the advertised resort’s website that the accommodation had several environmental initiatives that included the use of solar power, water treatment systems, and the operation of a nature reserve. However, that information had not been clearly explained in the ad. While the ad was short-form and was subject to space limitation, there was no indication of steps taken by the marketer to provide the information by other means (for example, by clearly and prominently setting it out on the linked landing page, one-click away), so that consumers could proceed with their consumer journey in an informed manner.
For those reasons we concluded the ad had not met the requirements of the Code.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), and 11.1 (Environmental claims).
Action
The ad must remain amended or withdrawn. We told Thomas Cook Tourism (UK) Company Ltd t/a Thomas Cook to ensure they made the basis of any environmental claims clear.
