ASA sharpens its focus on green advertising

The last week of June saw London Climate Action Week, and the Advertising Standards Authority (ASA) published a "pulse" study examining over seven million online ads.  It has also published several rulings on green claims across multiple sectors.

Pulse study

The ASA's pulse study, conducted using its Active Ad Monitoring system and AI-assisted analysis, examined ads served via Google search and website display advertising. The headline finding is that environmental claims remain relatively uncommon, appearing in only around 1% of the ads analysed. However, where such claims do appear, they are overwhelmingly framed in broad or absolute terms, e.g. words like "eco-friendly", "sustainable", or "carbon-neutral". Roughly three-quarters of the environmental claims identified were classified as absolute claims. 

This matters because, under the CAP Code, absolute environmental claims typically require a particularly high level of substantiation. The ASA concludes that the regulatory risk around green claims is shaped less by how often they appear and more by how they are framed. 

However, the study highlighted positive examples of advertisers using more specific and qualified environmental messaging. In sectors such as transport and utilities, many advertisers made comparative claims, for instance, about lower emissions on train travel compared with aviation, or reduced energy consumption compared with specified alternative products, rather than relying on broad, unqualified assertions. 

Sector by sector: where the ASA has intervened

Greener homes: Rulings have highlighted problems with ads for home energy products that failed to make clear the eligibility criteria for government grants, alongside pricing claims that did not reflect what most consumers were likely to pay. 

Fashion and sustainability: The ASA ran a series of cases examining environmental claims by clothing companies, including well-known brands. Where an absolute claim like "sustainable" is used, advertisers must make clear the basis of the claim if they intend it to refer to only a particular environmental benefit. Without measures to control the scope, consumers are likely to interpret it broadly, potentially as suggesting a product has a positive, or at least no adverse, impact on the environment across its full life cycle. 

Green disposal: Products such as nappies and wipes have attracted scrutiny, particularly around "biodegradable" claims. Evidence must account for real-world disposal conditions, and ads need to include information such as where the product must be disposed of to biodegrade properly, how long the process takes, whether any substances interfere with it, and whether any by-products or environmental harm result. 

Travel: Cruise operators have been found wanting on both absolute claims (e.g. "A Strong Focus on Sustainability and Eco-friendly Practices") and comparative claims (e.g. "LNG, the world's cleanest marine fuel"). Given the significant environmental impact of cruises, the ASA expects particular precision in this sector. Companies operating in high-polluting industries can advertise the work they are doing to lessen their impact, but must take care not to over claim. 

New guidance on the way

Alongside the pulse report, the Committee of Advertising Practice (CAP) is due to publish new guidance titled Green-speaking with confidence, designed to help advertisers make clear, evidence-based environmental claims. The ASA has indicated that the study's findings will inform future monitoring, engagement, and guidance work. 

For businesses, the practical takeaways are consistent across both publications. Consider whether a claim is absolute or comparative, and ensure the evidence held matches the likely consumer interpretation. Be precise in wording so that advertising does not slip into over claiming. And where there are qualifications or limitations to a green claim, make them clear. It is also worth noting that although the CMA has recently been concentrating on issues such as pricing and pre-selected optional extras, it has shown an interest in environmental issues in the past, notably in the fashion sector, and will look at ASA rulings as part of its work on assessing where it needs to concentrate its efforts.