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ASA updates its guidance on "carbon neutral" and "net zero" advertising claims

Posted on 17 March 2023

As the state of our environment becomes ever more important to consumers, brands are increasingly seeking to spotlight their green credentials in their advertising. Research undertaken by the ASA in 2021 showed that when it came to highlighting environmental credentials, "carbon neutral" and "net zero" were some of the most commonly encountered advertising claims. However only a small proportion of people actually understood what these terms meant, and of those people there was little consensus around the definitions.

What should brands look out for when advertising their green credentials?

In response to these findings, the ASA has updated its guidance: The environment: misleading claims and social responsibility in advertising which now contains additional guidance on the use of "carbon neutral" and "net zero" claims in advertising.

In particular, the updated guidance advises:

  1. Avoid unqualified claims: “carbon neutral”, “net zero” or similar claims should be avoided unless they can be substantiated. Advertisers should provide information to assert the basis of the claim allowing consumers to take account of such information before making decisions. As we noted in our article reviewing the first greenwashing complaint upheld against a bank, brands must provide evidence to assert their green claims and qualify those claims without being misleading in order to comply with advertising regulation.
  2. Verifiable strategy for future claims: Linked to the above, any claims based on future goals should be based on a verifiable strategy.
  3. Clarity regarding reducing vs offsetting: Accurate information is required as to whether, and if so the extent, carbon emissions are actively being reduced compared to whether they are offset. This is to aid consumers' understanding of whether their products generate no or fewer emissions.
  4. Evidence for offsetting: Advertisers should comply with the usual standards of evidence for claims and provide details of the offsetting scheme used.

How are regulators responding to brands' environmental claims?

Over the next six months, the ASA will monitor whether the updated guidance impacts the current state of advertising. It will also gather information to assess how such claims are being substantiated. If it concludes that, overall, the level of evidence is not satisfactory, it will invite the Committee of Advertising Practice (CAP) to review what forms of evidence are acceptable. As such, there could be further guidance in the near future.

Greenwashing issues continue to be a priority for a number of other regulators. In the last two years, the Competition Markets Authority (CMA) has published a green claims code, and in January 2023 it commenced investigations into a number of clothing retailers in relation to eco-friendly and sustainability claims. The Financial Conduct Authority (FCA) has proposed new rules to help tackle greenwashing including restricting the use of terms such as "green" and "sustainable". Greenwashing is not only an issue UK regulators are grappling with – the EU has potential new legislation which proposes fining companies for unsubstantiated green claims, with a proposed Directive expected to be published imminently.

Given these developments, greenwashing is undoubtedly a focal point for regulators both in the UK and more widely. As such, brands need to be alive to the rules before making environmental claims in their advertising.


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