Background
This ruling forms part of a wider piece of work on ads making carbon neutral delivery or similar claims. The ads were identified for investigation through both intelligence gathered by the ASA and the use of the Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules. See also related rulings published on 11 November 2026.
Ad description
A paid-for Meta ad for Who Gives A Crap, a toilet roll retailer, seen on 9 June 2026 featured a video of a person discussing the brand's history, that the rolls were made from either recycled or bamboo paper, and that they donated part of their profits. Text in the ad’s caption stated “[...] Carbon neutral shipping".
Issue
The ASA challenged whether the ad made the basis of the claim “Carbon neutral shipping” clear.
Response
Who Gives A Crap Ltd said that they intended for consumers to interpret "Carbon neutral shipping" as relating to the emissions involved in moving a purchased product from their factories to the customer's doorstep, and had deliberately referred to "shipping" to avoid suggesting they were referring to a completed product itself or their whole business being carbon neutral. They explained that, in terms of their logistics process, "shipping" referred to the transport from the manufacturing site to the port of origin, international ocean and air freight from the port of origin to the port of destination, inland transport from the port of destination to the warehouse, and final transport from the warehouse to the customer's address.
The emissions produced during the stages that "shipping" accounted for were offset via purchasing verified carbon credits. To ensure that the emissions from delivery were fully matched, a buffer of 10% was applied in terms of the number of credits purchased. They outlined that they did not regard offsetting as a substitute for active emissions reduction and that Who Gives a Crap was also investing in materially reducing its logistics and operational emissions at source, including via using onsite and purchased renewable energy across their warehousing operations, and using electric vehicles for the final delivery of their products where infrastructure supported them.
They were of the view that the ad had not omitted material information. That was because, while desirable from a consumer’s perspective, the addition of information about whether the claim “Carbon neutral shipping” was based on verified offsets would not have qualified or changed its overall impression. Nonetheless, they explained that in May 2026 they had begun a review of their environmental claims, and as of July 2026 the ad was no longer running and they had amended the banner on their website’s homepage, when it referred to carbon neutral shipping, to include a link to a page that explained the basis of the “Carbon neutral shipping” claim.
Assessment
Upheld
The CAP Code required that the basis of environmental claims must be clear and stated that unqualified claims could mislead if material information was omitted. CAP Guidance on “Misleading environmental claims and social responsibility in advertising” stated that advertisers should avoid using unqualified carbon neutral claims, and because information explaining the basis for those claims helped consumers’ understanding, such information should therefore not be omitted. It further stated that accurate information about whether (and the degree to which) the claim was based on an active reduction of carbon emissions or based on offsetting should be included in ads to ensure consumers understood the basis on which carbon neutrality was achieved. The ASA assessed the ad in question against the CAP Code, having regard to the CAP Guidance.
We accepted Who Give’s A Crap’s view that the claim “Carbon neutral shipping” would be understood as meaning that the shipping only, which included all transport from the manufacturing site to the customer’s address, rather than the full life cycle of their products, was “Carbon neutral”. We considered the claim, as it was presented in the ad, would be understood by consumers as meaning that steps had been taken to ensure that the shipping of their products did not result in a net increase in the amount of carbon being released into the atmosphere, but, from the ad, it was ambiguous if that was achieved via offsetting or via the actual removal of any sources of emissions.
We understood the claim depended on the use of offsetting credits. However, there was no information within the ad, its video or caption, which explained the basis of the “Carbon neutral shipping” claim, including by outlining whether, and the degree to which, the claim depended on an active reduction of carbon emissions or if it was based on the use of offsetting credits. We considered that the ad was not limited by time or space to the extent that the information could not have been provided. There was therefore sufficient space within the ad to make clear the basis of the claim “Carbon neutral shipping” so that consumers could proceed with their consumer journey in an informed manner. In addition, the ad’s landing page, when the ad had been seen, had not included information that explained the basis of the claim.
We welcomed that Who Gives A Crap had subsequently amended the banner on their website’s homepage, when it referred to carbon neutral shipping, to contain a link to a page that explained the basis of the “Carbon neutral shipping” claim and the ad had been withdrawn. However, as the ad had omitted material information that explained the basis of the “Carbon neutral shipping” claim, we concluded it was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising) and 11.1 (Environmental claims).
Action
The ad must not appear again in the form investigated. We reminded Who Gives A Crap Ltd to ensure that they made the basis of all environmental claims clear, including in relation to what extent any “Carbon neutral shipping” claims depended on the use of offsetting credits or the actual removal of any source of emissions.
