The Advertising Standards Authority (ASA) recognises the role that advertising can play in influencing consumer behaviour and helping the UK meet its climate targets while protecting consumers from misleading claims.

The Competition and Markets Authority (CMA) has new powers to enforce consumer laws and apply its own Green Claims Code.

Inside

• How are environmental claims regulated in the UK?
• What are the consequences for non-compliance?
• What is the difference between the ASA and CMA?
• Are there useful real-world examples?

How does the ASA regulate environmental claims?

The ASA applies the rules in the CAP and BCAP Codes. As well as a general obligation not to materially mislead consumers, and an obligation not to create advertising and marketing content that is ‘socially irresponsible’, there are specific rules relating to environmental claims:

• The meaning of all terms must be clear to consumers. There has been some debate about whether consumers understand commonly‑used terms such as ‘net zero’.
• The basis of the claim must be clear. Unqualified claims could mislead if they omit significant information necessary to understand the basis of the claim. If there are multiple possible interpretations to a claim, include additional information to make the meaning clear.
• The level of substantiation required will depend on the claim. Absolute claims require a very high level of substantiation. Comparative claims such as “friendlier” can be justified if the advertised product provides an overall benefit compared to the marketer’s previous product or a competitor product, and the basis of the comparison is clear.
  
  If the ASA considers a claim to be objective and capable of substantiation, they are likely to rule the claim misleading in the absence of adequate substantiation, even if the marketer’s intention was to make a subjective claim.
• General claims about the environmental credentials of products are likely to be interpreted as claims about the product’s entire lifecycle, from manufacture to disposal: such as “good for the planet”, “environmentally friendly”, “less plastic”, “give back to the environment”. If a general claim cannot be justified, a more limited claim about specific aspects of a product might be justifiable. For example, a claim that an electric car emits “zero tailpipe emissions” while driving may be acceptable (although there may be other issues related to the battery or the tyres and the ASA will look at the whole picture).
• Claims should not be presented as universally accepted if scientific opinion is divided.
• Products with no adverse effects on the environment must not falsely claim to be ‘improved’.
• Marketers may claim that a product has always been designed in a way that omits an ingredient or process known to harm the environment.
• Claims must not mislead consumers about a product’s environmental benefit: such as by highlighting an ingredient not usually found in competing products or a benefit that results from a legal obligation to which all competing products are subject.
• Marketing must have a sense of responsibility to consumers and to society. This is a general ‘catch all’ rule that gives the ASA broad discretion to decide a piece of content has breached the CAP or BCAP Code, even if it hasn’t breached another specific rule.

Consequences for non‑compliance with the CAP/BCAP Codes

If the ASA upholds a complaint, not only will that damage your reputation credibility with customers, the materials containing the claim would need to be removed (or amended to ensure compliance).

Examples of relevant ASA rulings

Pepsi Lipton Iced Tea (January 2022)

A poster for Lipton Iced Tea stated “DELICIOUSLY REFRESHING, 100% RECYCLED*”. The asterisk linked to small print at the bottom of the poster that stated, “Bottle made from recycled plastic, excludes cap and label”. A recycling logo and the text “I’M 100% RECYCLED PLASTIC” was also visible on the poster.

One complaint was made challenging whether the claim “100% RECYCLED” misleadingly implied that all of the bottle was made from 100% recycled plastic.

ASA’s decision: upheld

The ASA considered that consumers would understand the claim “100% RECYCLED” alongside images of the bottle, label, and cap to mean that all components were made entirely from recycled materials. Although there was a disclaimer, it lacked prominence and ultimately contradicted the absolute claim. The ASA therefore held that the claim was misleading.

Innocent Drinks (February 2022)

An ad for Innocent appeared on TV, as a video-on-demand (VOD) ad, and as a paid ad on YouTube.

The ad featured the lyrics “we’re messing up the planet... And filling up our bodies with more beige food than we should...” accompanied by images of pollution and unappetising food. A greener environment then appeared with the lyrics “Let’s get fixing up the planet…Be kinder to our bodies with nature’s tasty food…” and showed fruit being squeezed into an Innocent bottle. The song concluded, “Reduce. Re-use. Recycle. Because there is no planet B. If we’re looking after nature she’ll be looking after me”. A voice-over said, “Innocent. Little drinks with big dreams for a healthier planet.”

26 people complained (including Plastics Rebellion) that the ad exaggerated the total environmental benefit of Innocent’s products and was misleading.

ASA’s decision: upheld

The ad created a strong association between Innocent and a positive impact on the environment. Although the ad contained aspirational messaging, the overall message for many consumers would be that the purchasing of Innocent products had a positive environmental impact. This was reinforced by Innocent branding and products only being shown when the planet was being “fixed up”.

Innocent failed to provide evidence that demonstrated that buying Innocent products had a net positive environmental impact over their full lifecycles, as the ad implied. Innocent’s bottles also used non-recycled plastic and the ASA emphasised that the extraction and processing of those materials to produce the bottle would have a negative impact on the environment.

TotalEnergies (April 2025)

A complaint about a social media ad by TotalEnergies was ruled against for omitting information about their environment impact. The ad focused entirely on an example from the business’s electricity start-up accelerator programme and the support they had offered to a company that designed wind and solar farms. The ad clicked through to the TotalEnergies website, where more information was provided.

The ASA considered that the social media ad framed the programme and support as representative of the advertiser’s overall balance of work. However, a significant proportion of the energy products produced and sold by the advertiser were from fossil-fuels. More information was provided on the TotalEnergies’ website, but not on the page accessed directly via the click through.

Because the social media ad did not include information to balance out the message, it was considered misleading by omission.

ASA’s decision: upheld

Shell UK (April 2025)

In contrast, the ASA did not uphold complaints that a TV ad for energy company Shell gave a misleading impression of Shell’s environmental impact.

The ad’s main creative included visuals and a voice-over that referred to Shell’s provision of energy to the UK. It showed several functions including the installation of electric vehicle chargers and the delivery of energy into a home and highlighted the role it played in building skills for the energy transition. The ad featured imagery of a model windfarm and an offshore gas rig. Superimposed text set out the proportions of Shell’s Capital Expenditure that comprised oil and gas and lower-carbon initiatives.

The ASA concluded that the ad – across the visual, voice-over, and superimposed text – had provided a balanced picture of Shell’s overall business. They also considered that viewers would understand from the ad that Shell was active in both higher and lower carbon activity and through qualifying information that most of Shell’s investments were oil and gas, and to what degree. As such, the complaints were not upheld.

ASA’s decision: not upheld

Lacoste (December 2025)

Lacoste was one of three clothing brands challenged because of the ASA’s work investigating environmental claims in the fashion retail sector.

A paid for Google ad stated “Lacoste Kids – Sustainable… Clothing”. Lacoste explained it had been working on reducing its carbon footprint for several years. Since 2022, it had focused on the Lacoste Kids range by increasing the use of certified materials; at the time the ad was posted, around 78% of kids’ products sold online were made from these certified products. The “sustainable” claim was made on the basis that there was a reduction in the overall environmental footprint of materials. 

In its response, Lacoste cited a multi-year environmental strategy, and life cycle analyses indicating a reduction in environmental footprint for the 2025 collection compared to the 2022 collection.

However, Lacoste also acknowledged that general claims such as “green”, “sustainable” and “eco friendly” were difficult to substantiate, and removed the ad as soon as the complaint was received.

The ASA flagged than the basis of any environmental claim must be clear, based on the full life cycle of the advertised product, and supported by a high level of substantiation. It held that the comparison did not equate to substantiation of the absolute “sustainable” claim and concluded the ad was likely to mislead.

ASA’s decision: upheld

Nike (December 2025)

Nike’s paid-for Google ad for tennis polo shirts called out “sustainable materials”. 

The ASA challenged whether the “sustainable materials” claim was misleading. Nike argued that the claim was a generic reference to a wide range of its products and services, rather than being specific to a particular product or service. Characters were limited in the ad, and when the customer clicked the ad, they’d be directed to all products available – some of which were labelled as including “sustainable materials”.

While Nike pointed to the recycled polyester content (>75% in the relevant polo shifts) and cradle-to-gate data indicating reduced CO2 versus virgin polyester, the claim was not explained in the ad itself.

The ASA ruled that “sustainable materials” was an unqualified, absolute claim likely to be read to mean that the tennis polo shirts would not have any detrimental impact on the environment.  In the absence of evidence demonstrating there was no detrimental impact across the full lifecycle of the product, the ASA upheld the complaint.

ASA’s decision: upheld

Superdry (December 2025)

The ASA upheld a complaint against another paid-for Google ad by retailer Superdry. The ad stated: “Superdry: Sustainable Style. Unlock a wardrobe that combines style and sustainability”.

Superdry argued that it was intended to highlight that they manufactured, sourced and sold a range of products that had attributes including sustainable attributes. In their view, the ad did not suggest all products were sustainable.

While the evidence provided set out material composition and quantities, Superdry acknowledged that the full lifecycle of the products was not publicly available and removed the ad. 

The ASA referenced CMA guidance that states that general claims like “sustainable” are likely to mislead customers, and that a high level of substantiation would need to be produced to support such a claim.

ASA’s decision: upheld

Cheeky Panda (February 2026)

The ASA upheld all three challenges brought by a competitor against environmental claims made on The Cheeky Panda’s website for its bamboo nappies and baby wipes, finding that the claims “sustainable bamboo”, “100% sustainable bamboo fibre”, “biodegradable baby wipes”, “biodegradable fibres”, and “kinder to the planet […] protecting the planet” were misleading because they were presented as absolute environmental claims without adequate substantiation. The ASA found that Cheeky Panda had not provided product‑specific life‑cycle evidence to support sustainability claims, that the biodegradability evidence related only to viscose fibres rather than the wipes as a whole under real‑world disposal conditions, and that claims suggesting environmental superiority or planet‑protecting benefits were not explained or supported by robust comparative evidence. As a result, the ASA ruled that the ads breached CAP Code rules on misleading advertising and environmental claims, required that the ads not appear again in their current form, and instructed Cheeky Panda to ensure clear bases and strong substantiation for future environmental claims.

ASA’s decision: upheld

Kit & Kin (February 2026)

The ASA upheld three challenged raised by a competitor against environmental claims on Kit & Kin’s website for its “Eco nappies & wipes” range, finding that the overall presentation — including claims such as “Protecting Your World, Naturally”, “better for our world”, “sustainable”, and “biodegradable” — gave a misleading impression of the products’ environmental impact. The ASA considered the advertising suggested the nappies and wipes caused no environmental harm throughout their life cycle and that purchasing them contributed to rainforest protection, yet Kit & Kin did not provide sufficient evidence to substantiate such absolute or comparative environmental claims, nor did the ads explain their basis. The ASA found the “sustainable” claims were unqualified and unsupported by full life‑cycle evidence, particularly as the nappies contained plastic components, and that the “biodegradable” claim misleadingly implied the wipes would fully biodegrade in all real‑world disposal conditions, which was not evidenced. The ads breached CAP Code rules on misleading advertising and environmental claims, and the ASA instructed Kit & Kin to ensure future environmental claims are clearly explained and supported by robust substantiation.

ASA’s decision: upheld

Key takeaways:

• It is very risky to rely on disclaimers to qualify absolute claims such as “100% recycled”.
• Very broad environmental claims (such as “environmentally friendly” or “sustainable”) are likely to be considered misleading.
• Specific claims are safer, but be careful not to be too ‘selective’ if that gives a misleading impression. The ASA is more likely to be sympathetic to advertisers who balance positive messages with honest admissions about their current impact during their transition.

ASA guidance on “carbon neutral” and “net zero” claims (February 2023)

ASA research into consumer understanding of claims such as “net zero” and “carbon neutral” showed that consumers didn’t fully understand what terms like these meant. Some of the consumers interviewed as part of the research were surprised and ‘disappointed’ that many of these claims were based on carbon offsetting, more so than carbon reduction. So, in February 2023, the ASA published updated guidance. In summary, it stated that advertisers should avoid using unqualified carbon neutral, net zero or similar claims. Advertisers should include accurate information about whether (and the degree to which) you are actively reducing carbon emissions or are basing claims on offsetting. Claims based on future goals relating to reaching net zero or achieving carbon neutrality must be based on a verifiable strategy to deliver them. Claims based on offsetting require objective substantiation. Necessary qualifying information about a claim should be sufficiently close and prominent to the claim so consumers can take them into account before making a decision.

Updated ASA guidance on misleading environmental claims and social responsibility in advertising (November 2025)

In November 2025 the ASA published updated guidance on misleading environmental claims and social responsibility in advertising.  The guidance covers the basis of claims, claims about initiatives designed to reduce environmental impact, green disposal claims, clarity of terms such as net zero and carbon-neutral, substantiation, the full lifecycle, scientific opinion, adverse effects and environmental benefit.  It also covers various aspects of social responsibility.

The ASA uses AI tools to monitor online advertising for problematic claims, so even if nobody complains about your advertising, the ASA may find and investigate it anyway.

Update on the CMA’s involvement in environmental claims

The CMA published new guidance on green claims in the supply chain in January 2026 and is still very interested in misleading green claims.  It uses the Digital Markets, Competition and Consumers Act 2024 to bring enforcement action against companies that mislead consumers in relation to environmental claims. The CMA has also published its own guidance called the Green Claims Code.

The CMA and ASA’s remits do overlap, but the CMA’s jurisdiction is wider – it includes point-of-sale, packaging and labelling, in addition to media covered by the ASA’s remit such as websites, social media, advertising and marketing content, and so on.  The CMA will look at ASA rulings to decide if there are problems it needs to consider.

Sectors in the CMA’s crosshairs

In 2022, the CMA focused on the fashion sector. It was particularly interested in the following issues:

• the statements and language used by the businesses, and whether these are too broad and suggest that clothing collections are more environmentally sustainable than they actually are
• the criteria used by some of these businesses to decide which products to include in these collections and whether this is lower than customers might reasonably expect from their descriptions and overall presentation
• whether there is a lack of information provided to customers about products included in any eco ranges, such as missing information about what the fabric is made from
• any statements made about fabric accreditation schemes and standards, which the CMA is concerned could be potentially misleading, such as a lack of clarity as to whether the accreditation applies to particular products or to the firm’s wider practices.

In 2024 it issued guidance for the fashion industry on green claims.

FMCG sector

In January 2023, the CMA announced a review of environmental claims in the fast-moving consumer goods sector (“FMCG”). It said that problematic claims in these sectors included:

• the use of vague and broad eco- statements such as describing a product or packaging as “sustainable” or “better” for the environment with no evidence,
• misleading claims about the use and extent of recycled or natural materials in a product,
• incorrectly branding entire ranges as ‘sustainable’.

In late 2024 it closed its investigation for reasons of administrative priority, but it seems clear that the CMA will continue to review green claims in this and other sectors and use its new powers to enforce the law. 

FCA Sustainability Disclosure and Labelling Regime

The Financial Conduct Authority (FCA) Sustainability Disclosure and Labelling Regime is a package of new rules and guidance aimed to help consumers navigate the market for sustainable investment products. From 31 May 2024, all FCA-authorised firms became subject to a new anti-greenwashing rule when making claims about the sustainability of their products and services. This rule is designed to ensure claims are fair, clear, not-misleading and proportionate to the sustainability profile of the product and service. 

At the end of 2024, the FCA’s naming and marketing rules with accompanying disclosures came into force. The naming and marketing rules were designed to ensure accurate use of sustainability-related terms, whilst the accompanying disclosures aimed to ensure that consumers are provided with better, more accessible information to help them understand the key sustainability features of a product. Investment labels have been available for products with sustainability objectives since 31 July 2024 although use of these is non-mandatory. Distributors of investment products to UK-based retail investors are also subject to additional, targeted rules.

As well as this, the FCA launched a consultation on replacing the current sustainability disclosure rules for in-scope listed companies with UK Sustainability Reporting Standards. The FCA aims for the rules to come into force from 1 January 2027

EU rules

As well as the UK rules, don’t forget that if you are advertising to consumers in the EU you need to consider EU laws as well.  The Green Transition Directive comes into force in 27 September 2026 and updates the Consumer Rights Directive and the Unfair Commercial Practices Directive.  Its provisions are beyond the scope of this note, but the key points are:

• Requiring traders to provide consumers with new sustainability information pre-contract, such as in relation to a product's reparability and durability.
• Banning or otherwise tackling unfair commercial practices that prevent consumers from making sustainable consumption choices, such as greenwashing.

Generic claims are prohibited unless supported by verifiable evidence. Claims reliant on offsetting must be independently certified.