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 24 June 2025.
Ad description
A paid-for Google ad for UNIQLO, a fashion retailer, seen on 25 December 2025, stated “Fleece Coats & Jackets – UNIQLO Women’s Range […] Shop UNIQLO Fleece Coats & Jackets Now […] Recycled Materials”.
Issue
The ASA challenged whether the claim “recycled materials” was misleading and could be substantiated.
Response
UNIQLO Europe Ltd t/a UNIQLO said that the ad promoted fleece coats and jackets from their women’s range and that consumers were likely to understand “Recycled Materials” to mean that the fleece jackets or coats referred to in the ad were made, to a meaningful extent, from recycled materials.
The claim “Recycled Materials” was intended to communicate that the polyester materials used in the relevant products were made from recycled polyester, specifically recycled post-consumer PET (polyethylene terephthalate) sources. UNIQLO said that the claim did not suggest that every component of the garments, such as the metal zipper or the labels, were recycled but rather the claim referred to the textile materials that made up the main body fabric and with the fabrics used in the lining and trim.
UNIQLO provided a screenshot of the landing page that the ad clicked through to. It listed three items, the Fluffy Yarn Fleece Full-Zip Jacket, the Pile Lined Fleece Relaxed Cardigan, and the Knit Fleece Full-Zip Jacket.
UNIQLO explained that their claims were supported by independent verification by a recognised international certification scheme. They provided material composition data for each of the three items listed on the landing page together with relevant certificates issued by the certification scheme in order to demonstrate the presence of recycled content from the initial stages of manufacturing to the finished product.
Assessment
Upheld
The CAP Code required that the basis of environmental claims must be clear and stated that unqualified claims could mislead if they omitted material information. It also required that absolute environmental claims must be supported by a high level of substantiation.
The Competition and Markets Authority guidance ‘Complying with consumer law when making environmental claims in the fashion retail sector’ (the CMA Guidance) stated that advertisers should not imply that a product is entirely made of a single fabric if that was not true. A product should not be described as, for example, “recycled” or “organic” if it contained fibres that were not recycled or organic, unless the proportion of non-recycled or non-organic fibres was negligible. The ASA had regard to the guidance in assessing whether the ad had complied with the CAP Code.
The ad stated “Fleece Coats and Jackets – UNIQLO Women’s Range […] Shop UNIQLO Fleece Coats & Jackets Now […] Recycled Materials”. As the ad did not include information explaining the basis of the claim “Recycled Materials”, we considered consumers would interpret the claim as absolute. In the context of the ad, the claim “Recycled Materials” was likely to be understood as meaning that all of the fabrics used in the fleece coats and jackets referred to in the ad were made entirely from recycled materials. The ad linked through to a landing page that listed three items, the Fluffy Yarn Fleece Full-Zip Jacket, the Pile Lined Fleece Relaxed Cardigan, and the Knit Fleece Full-Zip Jacket.
The claim in the ad was absolute and, therefore, a high level of substantiation in support needed to be produced. We expected to see evidence to show that all three items listed on the ad’s landing page were made entirely from recycled materials.
We reviewed the evidence that UNIQLO provided. We acknowledged that each of the products listed on the landing page contained some recycled materials. However, the evidence did not demonstrate that each of the products was entirely made from recycled fabrics. For that reason, we considered the ad’s claim had not been adequately substantiated.
The basis of the claim “Recycled Materials” had not been made clear and we had not seen evidence to support it, as consumers were likely to understand it. We therefore concluded that the ad was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), 3.7 (Substantiation), 11.1 and 11.3 (Environmental claims).
Action
The ad must not appear again in the form investigated. We told UNIQLO Europe Ltd t/a UNIQLO to ensure that their future ads made the basis of any environmental claims clear and did not suggest that their products were entirely made from recycled materials when that was not the case, and that a high level of substantiation must be held to support absolute claims.
