Ad description

A paid for Facebook post and a poster ad for Toyota:

a. The Facebook post stated, “From Active Traction Control to Hill Start Assist, Toyota Hilux, Born to Roam”. An accompanying video showed a wide open plain with mountains either side. A swarm was depicted from a distance moving across the plain, causing dust to rise. A number of Sports Utility Vehicles (SUVs) were then shown moving across the landscape in unison before joining a tarmacked road. A voiceover said, “One of nature’s true spectacles.” The vehicles were then shown on the road, side by side, and driving through a built-up city area with a single vehicle then shown reversing up a driveway. The voiceover continued, “Toyota Hilux. Born to Roam.” A final shot showed the car parked in a rocky, natural environment. Text stated “WWW.TOYOTA.CO.UK BORN TO ROAM Learn more”.

b. The poster, seen at a bus stop, stated, “BORN TO ROAM”. An image showed two SUVs driving on a rocky incline in a savannah style landscape. Around 50 identical SUVs appeared in a large pack on a hilly background.


Adfree Cities, who believed the ads condoned behaviour that was harmful to the environment, challenged whether they were irresponsible.


Toyota (GB) plc explained that they were committed to positive environmental change and had introduced several hybrid and electric vehicles across their range since 1997. In addition, they had granted hundreds of royalty-free licences for the use of their hybrid technology. All of which demonstrated the importance they gave to environmental responsibility.

They said the ads had been through a thorough checking process for both technical capability claims and wider generic claims for the vehicle and/or the brand.Regarding ad (a) they said the footage of the vehicles off-road was minimal and when they appeared they were never in an environment which was ecologically sensitive or a habitat with wildlife. Further to that the terrains depicted in the ads were all areas for which the vehicle was designed.. The Hilux was meant for the toughest environments and certain industries had a genuine need for off-road which included specialised workers such as farmers, forestry workers and park rangers. They said they were entitled to advertise to those markets and should be allowed to depict suitable off-road environments to demonstrate the off-road capabilities of the vehicle. However, they stated that they should be allowed to do that in a way that was not restrictive and did not involve depicting a specialised worker character or scenario in the ads. They further stated that if ads were able to show cars on race tracks or circuits, then off-road environments should also be permissible.

The video had been shot in Slovenia on private land, with permission, and it was unlikely that viewers would see the environment depicted as being in the UK. They explained that the use of multiple vehicles, which they believed was clearly fantastical, added to the argument that a viewer was unlikely to replicate the ad in the UK countryside. They said that the fantastical presentation of the large number of vehicles would prevent consumers emulating the ad and driving in large numbers in the wild.

They explained that despite the Hilux’s off-road capabilities, and the need to make specialised purchasers aware of that, they limited the off-road footage because of their dedicated environmental stance and consideration for social responsibility. They said as a result, based on screen time, the emphasis of the ad was not on the off-road scenes.

Specifically there were four off-road scenes taking up 11 to 12 seconds of a 30-second video. The first scene was in a desert with mountains either side. It was shot from the middle distance and so it would not have been possible to identify the terrain but there was nothing to say it was inappropriate for car use. In addition, the number of cars, the trailer and background gravel indicated that the vehicles were on a road or unpaved road. A close up in one scene indicated a dusty, unpaved road. The second scene showed a forest surrounding an open gravel plain. The ground of the open plain had visible tyre tracks, indicating it was a regularly used off-road path. A third scene featured a visibly beaten track or unpaved road suggesting regular use. The track joined a public road and so indicated that it was suitable for and designed for vehicles. The fourth scene showed the car parked and did not indicate any irresponsible off-road use.

They explained that the speed of the vehicles in the ad was appropriate and while dust was shown when the cars moved, that was not an example of irresponsible driving. They further said that the line “One of nature’s true spectacles” was a reference to a herd of vehicles and not to damage or destruction of a natural setting.

Toyota believed no reasonable viewer would have understood the ad as encouraging UK consumers to drive irresponsibly in the UK countryside and cause environmental harm.Regarding ad (b) they said the image had been created completely by computer generated imagery (CGI) and so caused no damage to the natural environment. They understood the image would be seen as similar to a herd of wildebeests and therefore fantastical. In addition, and similar to ad (a), the landscape, which was akin to African plains, bore no resemblance to the UK or UK countryside, which indicated again that the ad was fantastical and would not lead to UK consumers emulating the large number of vehicles in the wild.

They said that the slogan ‘Born to Roam’ was intended to reflect the ability of the car to operate off-road and cope with different terrain. They believed it would not be interpreted as encouraging or excusing driving behaviour that was negative to the environment. They said an off-road vehicle by definition was one used for rough terrain and the slogan ‘Born to Roam’, alongside the images and videos, visually represented that definition.



Marketing communications must be prepared with a sense of responsibility to consumers and to society.

The ASA acknowledged Toyota’s comments that the sheer volume of cars in the ads would lead viewers to interpret the scenes as fantastical and not as a portrayal of real-world driving.

Ad (a) initially presented a large volume of cars in a rural setting seen from a distance, all moving as one across an open landscape in a manner that some viewers might infer was analogous to a herd of animals and therefore might be viewed as fantastical. However, the scenes that followed in ad (a) showed a much smaller number of cars at close-up, driving realistically at speed across an untarmacked, off-road landscape including across a river. Toyota had explained that some of the rural scenes in ad (a) were on roads or unpaved tracks. However, that was not clear in the ad. The emphasis of the ads was on the off-road settings displayed and the vehicle’s movement without restriction, which was highlighted by the messaging, “One of nature’s true spectacles” and “Born to roam”. The latter scenes saw the vehicles driving realistically on roads, and in heavily built-up urban settings, with a final scene again depicting one vehicle parked in an off-road landscape. Ad (b) also showed a number of vehicles in the distance and two prominent vehicles close up, which were depicted realistically in an off-road setting.

The vehicles in ad (a) travelled across untarmacked plains and through rivers, with dust and scree visibly disturbed. In ad (b) the main vehicle appeared on a rocky slope, and other vehicles in the background travelled across similar terrain as seen in ad (a). While we acknowledged Toyota’s point that they were in part targeting specialised vehicle users, such as farmers or forest workers, who might legitimately need to use vehicles in rural or off-road environments, those scenarios were not represented in the ad, which included driving by unidentifiable categories of vehicle users in both rural and urban environments. We therefore considered that the impression given by the driving scenes and messaging in both ads was one of driving regardless of its purpose, across off-road environments and natural ecosystems which had no regard for the environmental impact of such driving.

The ads presented and condoned the use of vehicles in a manner that disregarded their impact on nature and the environment. As a result, they had not been prepared with a sense of responsibility to society.The ads breached CAP Code (Edition 12) rule 1.3 (Compliance).


The ad must not appear again in the form complained of. We told Toyota (GB) plc to ensure their future marketing communications contained nothing that was likely to encourage irresponsible behaviour towards the environment.

CAP Code (Edition 12)


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