New guidelines from advertising watchdog advises firms to clarify what they mean by 'carbon neutral' and 'net zero' marketing claims
The UK's advertising watchdog has published new guidance that aims to provide advertisers with more clarity on how to avoid misleading claims when promoting their 'carbon neutral' or 'net zero' status.
The Committee of Advertising Practice (CAP) and the Committee of Broadcast Advertising Practice (BCAP) last week published an update to their official guidance, titled The environment: misleading claims and social responsibility in advertising, which includes new guidance on the use of 'carbon neutral' and 'net zero' claims in advertising material.
Adherence to the new guidance by advertisers will now be reviewed by the Advertising Standards Authority (ASA), which acts as the self-regulatory body for the advertising industry and as such polices the codes established by CAP and BCAP.
The new guidance follows work by both the ASA and the Competition and Markets Authority (CMA) to crack down on 'greenwashing' claims from businesses that overstate their environmental credentials.
In 2021 a major investigation from the ASA identified consumer understanding of 'carbon neutral' and 'net zero' claims in advertising as a priority area for research, given their increasing prevalence and the potential for consumers to be misled.
The research found there was 'little consensus' on the meaning of the terms with claims around offsetting and net zero goals a particular source of confusion. "Participants tended to believe that carbon neutral claims implied that an absolute reduction in carbon emissions had taken place or would take place," the ASA said. "When the potential role of offsetting in claims was revealed, this could result in consumers feeling that they had been misled."
As such, the updated guidance calls on advertisers to "avoid using unqualified carbon neutral, net zero or similar claims", arguing that "information explaining the basis for these claims helps consumers' understanding, and such information should therefore not be omitted".
It also calls for marketers to ensure they include accurate information about whether - and the degree to which - they are actively reducing carbon emissions or are basing claims on offsetting, so as to ensure consumers do not wrongly assume that products labelled as 'carbon neutral' inherently generate no or few emissions.
And the guidance warns that where claims are based on offsetting, they should comply with the usual standards of evidence for objective claims and should include information on the offsetting schemes used.
"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 guidance states. "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."
Significantly, the guidance also advises that "claims based on future goals relating to reaching net zero or achieving carbon neutrality should be based on a verifiable strategy to deliver them".
The guidance could have major implications for green business advertising campaigns and will require firms to include more detailed information in support of their 'carbon neutral' or 'net zero' claims if they are to minimise the risk of being accused of misleading their audience.
The ASA said it will not undertake a six month monitoring exercise to assess whether the new guidelines are being adhered to and gather information on how claims are being substantiated.
"If that monitoring concludes that carbon neutral/net zero claims are being made but the types of evidence that underpins them is questionable, the ASA will invite CAP to 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," it said in a statement. "That review will take account of expert insights, policy developments in the UK and other jurisdictions and, where appropriate, consultation with interested parties."
However, it also warned that in the meantime previous guidance could still result in unqualified green claims being classified as 'misleading' by the watchdog.
"The ASA 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," it said. "Unqualified claims are likely to breach existing rules, and the ASA will be taking proactive action immediately to address such claims."
