ASA updates guidance on misleading environmental claims

Understanding the ASA’s stricter approach to green advertising

Environmental claims in advertising now face considerably tighter scrutiny. The Advertising Standards Authority has updated its guidance to require businesses to be specific, precise, and honest about what their green marketing actually means. Vague terms such as “eco-friendly” or “sustainable” are no longer acceptable unless the advertiser can prove exactly what those words mean in context. This shift reflects growing regulatory concern about misleading environmental marketing.

The updated position is straightforward. Ads must not omit important information. Claims must be based on the full life cycle of a product or service unless the ad clearly states otherwise. Unqualified statements such as “carbon neutral” or “net zero” are not permitted without a full explanation of the basis for them. Consequently, businesses need to show what the claim covers, what it does not cover, and what evidence supports it.

For UK businesses, this matters because environmental claims are increasingly important in customer communications, tender responses, and brand positioning. However, getting these claims wrong can result in regulatory action, reputational damage, and loss of customer trust. The guidance provides a framework for making legitimate environmental claims while avoiding the pitfalls of greenwashing.

What the ASA now expects from environmental marketing

The regulator has set out clear expectations. Advertisers must make the scope of any environmental claim explicit. If a claim applies only to one product, one activity, or one part of the business, that limitation must be obvious to consumers. A positive statement about a single initiative can mislead if the business still has a significant overall environmental impact, unless balancing information is provided.

Absolute claims require a high level of evidence. Terms such as “sustainable,” “eco-friendly,” or “environmentally friendly” are considered absolute unless qualified. This means businesses must be able to substantiate these claims across the full environmental footprint of the product or service. Partial improvements are not sufficient to support absolute language.

Imagery also matters. Natural scenery, leaves, blue skies, and similar visuals can create an exaggerated impression of environmental benefit if they are not supported by the substance of the ad. The ASA has ruled against campaigns where the imagery suggested a level of environmental performance that the product did not deliver. Visual elements are treated as part of the overall claim, not as decoration.

Standards and certifications must be explained. If an ad references compliance with a standard, it should give consumers enough information to understand what that standard means. Simply displaying a logo or badge is not sufficient unless the average consumer would understand its significance. Similarly, recycling claims need limitations made clear, particularly regarding infrastructure and what can actually be recycled in practice.

Offsetting claims must not imply that emissions do not exist when they do. The ASA has been explicit that offsetting is a form of compensation, not elimination. Therefore, claims must distinguish between actual emissions reductions and offsetting activities. This distinction is particularly important for “carbon neutral” claims, which must explain the extent to which neutrality relies on offsets rather than direct reductions.

Future commitments are treated as future commitments. Claims about net zero or other long-term ambitions should be backed by a verifiable delivery plan, with timeframes stated where material. Aspirational language is acceptable, but it must not mislead consumers into thinking future targets have already been achieved. The regulator expects businesses to be clear about what they have done, what they are doing, and what they plan to do.

How the rules apply to business communications

These requirements apply across all marketing communications, including websites, social media, brochures, and advertising. The ASA’s remit covers non-broadcast advertising, which means most business communications fall within scope. Consequently, businesses need to review all sustainability messaging, not just formal advertising campaigns.

The practical impact is that marketing teams must work closely with sustainability, compliance, and legal functions. Environmental claims should be based on internal data and verified before publication. Many businesses have found that claims previously considered acceptable no longer meet the updated standards. For example, a claim that a product is “environmentally friendly” might have been acceptable in the past, but now requires specific evidence about every stage of the product’s life cycle.

Third-party agencies also need clear guidance. External marketing agencies may not understand the technical basis for environmental claims or the limitations that apply. Businesses should ensure that agencies do not use broad claims without approval and evidence. This requires clear briefing, review processes, and sign-off procedures for any sustainability-related content.

Training is increasingly important. Marketing teams need to understand what constitutes a green claim, what evidence is required, and how to communicate environmental information without overstatement. This is not just about legal compliance. It is also about ensuring that customer-facing teams can answer questions about environmental claims with confidence and accuracy.

Commercial implications for UK businesses

The commercial risk extends beyond regulatory action. An ASA ruling against a campaign can result in significant reputational damage, particularly if the case attracts media attention. Customers, investors, and supply chain partners increasingly expect businesses to communicate environmental performance honestly. A greenwashing accusation can undermine trust and affect commercial relationships.

For businesses bidding for public sector contracts, environmental claims are often scrutinized during the tender process. Procurement Notice 06/21 requires suppliers to commit to net zero by 2050 and publish a carbon reduction plan for contracts above certain thresholds. However, these commitments must be consistent with public marketing claims. Inconsistencies between tender submissions and advertising can raise questions about credibility.

The guidance also affects product development and positioning decisions. Businesses may need to reconsider how they describe environmental benefits, particularly for products with mixed environmental performance. A product that uses recycled content but has high emissions during manufacture presents a communication challenge. The ASA’s guidance suggests focusing on specific, verifiable attributes rather than broad environmental claims.

There are also implications for supply chain communications. Many businesses make environmental claims based on supplier data or certifications. However, the advertiser remains responsible for the accuracy of the claim, even if the information came from a third party. Therefore, businesses need to verify supplier information and understand the basis for any environmental claims in their supply chain.

The updated standards may require changes to packaging, labeling, and point-of-sale materials. Claims that were previously acceptable may need to be qualified or removed. This can involve costs for reprinting materials, updating websites, and retraining sales teams. However, the cost of non-compliance is likely to be higher, both in regulatory terms and reputational impact.

Five core principles for compliant environmental claims

Several principles emerge from the ASA’s guidance. First, be specific about what the claim covers. Instead of saying a product is “sustainable,” explain which aspect of sustainability the claim refers to. For example, “made from 100% recycled plastic” is specific and verifiable. “Sustainable” is not.

Second, keep evidence on file and ensure it is robust. The ASA expects advertisers to hold substantiation for any environmental claim. This evidence should be based on recognized standards or methodologies where possible. Internal assessments may be acceptable, but they need to be thorough and transparent.

Third, consider how an ordinary consumer will understand the claim. The ASA assesses claims from the perspective of the average consumer, not an expert. Therefore, technical accuracy is not sufficient if the overall impression is misleading. A claim that is literally true but creates a false impression will still breach the rules.

Fourth, provide balancing information where necessary. If a business has a significant ongoing environmental impact, positive claims about one initiative may need to be balanced with context about the overall footprint. This does not mean businesses cannot make positive claims, but those claims must not mislead about the overall environmental performance.

Fifth, treat future goals as future goals. Commitments to achieve net zero or other long-term targets are legitimate, but they must be clearly presented as future ambitions. The claim should include the timeframe and, where material, an outline of how the goal will be achieved. Vague commitments without delivery plans are unlikely to be acceptable.

What businesses should do now

Businesses should start by reviewing all current environmental claims in marketing materials, websites, and customer communications. This review should assess whether each claim meets the updated standards for specificity, substantiation, and clarity. Many businesses have found that this process identifies claims that need to be qualified, removed, or better explained.

Marketing teams should receive training on the updated guidance. This training should cover what constitutes an environmental claim, what evidence is required, and how to communicate environmental information accurately. It should also address common pitfalls, such as relying on imagery that exaggerates environmental benefits or using absolute terms without sufficient evidence.

Businesses should establish clear approval processes for environmental claims. This might involve requiring sign-off from sustainability, legal, or compliance teams before any environmental claim is published. The process should ensure that claims are based on verified data and that the evidence is documented and accessible.

Third-party agencies need clear briefing on what is acceptable. Businesses should provide agencies with approved messaging, evidence files, and clear guidance on what claims can and cannot be made. Agency contracts should clarify responsibility for compliance and require agencies to seek approval for any environmental claims.

Finally, businesses should consider how environmental claims fit within their broader sustainability strategy. Marketing should reflect genuine environmental performance, not create an impression that cannot be supported. Therefore, improving environmental performance and communicating it honestly should be part of the same process. Our compliance support for carbon reporting and ESG requirements helps businesses build the evidence base for legitimate environmental claims.

Where to find detailed guidance

The ASA has published comprehensive guidance on environmental claims, available on the Advertising Standards Authority website. This guidance includes examples of acceptable and unacceptable claims, along with the regulator’s reasoning. Businesses should review this guidance in detail, particularly the sections relevant to their sector and products.

The Competition and Markets Authority has also published a Green Claims Code that sets out principles for environmental claims across all consumer-facing communications. This code complements the ASA’s guidance and provides additional context on substantiation and evidence requirements.

The Department for Business and Trade provides guidance on environmental claims in the context of consumer protection law. This guidance is available on gov.uk and covers the legal framework for misleading advertising and unfair commercial practices. Businesses should be aware that breaches of advertising standards can also raise issues under consumer protection law.

For businesses in specific sectors, trade bodies may provide additional guidance on environmental claims. For example, the Chartered Institute of Marketing offers resources on ethical marketing, and sector-specific bodies often provide guidance on common claims in their industries. These resources can help businesses understand how the ASA’s principles apply to their particular products or services.