The recommendations (the environment: misleading claims and social responsibility in advertising) are now in line with the Competition and Markets Authority’s guidance on environmental claims on goods and services.
The move follows the ASA’s Climate Change and the Environment project last year which concluded that consumer understanding of “carbon neutral” and “net zero” claims in advertising are a priority area for research, given their increasing prevalence and the potential for consumers to be misled by them.
In light of the low understanding and lack of consensus around the meaning of carbon neutral and net zero claims, CAP and BCAP now advise advertisers to take into account the following guidance, which if followed, means that "claims are less likely to mislead":
- Avoid using unqualified carbon neutral, net zero or similar claims. Information explaining the basis for these claims helps consumers’ understanding, and such information should therefore not be omitted.
- Marketers should ensure that they include accurate information about whether (and the degree to which) they are actively reducing carbon emissions or are basing claims on offsetting, to ensure that consumers do not wrongly assume that products or their manufacture generate no or few emissions.
- Claims based on future goals relating to reaching net zero or achieving carbon neutrality should be based on a verifiable strategy to deliver them.
- Where claims are based on offsetting, they should comply with the usual standards of evidence for objective claims set out in this guidance, and marketers should provide information about the offsetting scheme they are using.
- Where it is necessary to include qualifying information about a claim, that information should be sufficiently close to the main aspects of the claim for consumers to be able to see it easily and take account of it before they make any decision. The less prominent any qualifying information is, and the further away it is from any main claim being made, the more likely the claim will mislead consumers. For further information, see CAP’s guidance on the use of qualifications.
Next steps
The ASA said it will now carry out monitoring for up to six months, through which it will assess the impact of the Advertising Guidance on carbon neutral and net zero claims in advertising. It will also gather information to assess how such claims are being substantiated.
If that monitoring concludes that carbon neutral/net zero claims are being made with what it called “questionable evidence” the ASA will launch a review which would seek to provide guidance about what forms of evidence are more or less likely to be acceptable to substantiate such claims in advertising.
In the meantime, the ASA revealed it is aware that some organisations are making carbon neutral and net zero claims “which are entirely unqualified and do not explain the basis on which they are being achieved”. Unqualified claims, it said, are likely to breach existing rules, and the ASA will be taking “proactive action immediately” to address such claims.
