It’s not that easy being ‘green’ – promoting good work without misleading by omission

Jun 5th '24

Advertising Standards Authority (ASA) environmental work continues apace, and one issue that’s resulting in some advertisers falling foul of our rules is where an ad leaves out information about a brand’s environmental impact, giving consumers only a partial, biased view of only the positive projects that a brand is working on. A fundamental principle of our environmental rules, in Committee of Advertising Practice (CAP) Code rules, is that “unqualified claims could mislead if they omit significant information.” 


While the work being described in ads is often very positive, leading to reductions in emissions and climate-positive results, ads that focus only on this, without providing more context about the wider framework of a brand’s overall environmental impact, are likely to breach this rule.


Some of the most highly publicised of the ASA’s recent rulings have dealt with omissions like this, from airlines not making clear the level of their environmental impact when talking about aspirational future claims, banks not being clear enough about the level of their investments in high-polluting industries, to a water company’s ad which the ASA recently ruled against because it omitted information about the negative impact of some its work.


This last ruling was published in conjunction with another ad for a water company, which the ASA considered was compliant with the rules. These two rulings highlight another vital point – the importance of having substantive evidence to back up any claims being made.


The ASA concluded that Severn Trent had successfully demonstrated that it had, in its sector, a recent history of good environmental performance, and therefore claims such as “This is Severn Trent water. Our water. That’s why we’re working towards protecting it, nature, and our future by planting a bucket load of trees” were unlikely to mislead viewers. By contrast, complaints about Anglian Water’s ad focusing on its creation of wetlands were upheld, in part because the same Environmental Performance Assessment which showed Severn Trent performing relatively well, demonstrated that Anglian had been performing below their targets.


As more brands focus on their environmental aspirations, perhaps for 2030 or 2050, and talk about the positive results that their work to reduce emissions is having, it’s important to remember that the ASA will expect ads to make clear that these claims are made in the wider context of a company’s environmental impact, and that ads that solely focus on environmentally-positive projects are likely to breach the Code if they omit material information about the brand’s wider impact.


CAP has updated guidance on misleading environmental claims to help advertisers and agencies make sure environmental claims are always given clear context, and that they don’t mislead by omission.


Source: CAP


About CAP

The CAP is the sister organisation of the ASA and is responsible for writing the Advertising Codes.


About us

LS Consultancy are experts in Marketing and Compliance, and work with a range of firms to assist with improving their documents, processes and systems to mitigate any risk.


We provide a cost-effective and timely bespoke copy advice and copy development services to make sure all your advertising and campaigns are compliant, clear and suitable for their purpose.


Our range of innovative solutions can be tailored to suit your unique requirements, no matter whether you’re currently working from home, or are continuing to go into the office. Our services can be deployed individually or combined to form a broader solution to release your energies and focus on your clients.


Contact us today for a chat or send us an email to find out how we can support you in meeting your current and future challenges with confidence.


Explore our full range today.


Need A Regulatory Marketing Compliance Consultant? A Bit More About Us


Contact us


Why Not Download our FREE Brochures! Click here.


Call Us Today on 020 8087 2377 or send us an email.


We welcome individual bloggers / Professional Writers / Freelancers to submit high quality contents. Find out more…



Connect with us via social media and drop us a message from there. We’d love to hear from you and discuss how we can help.


Facebook | Instagram | LinkedIn | X (formerly Twitter) | YouTube


Contact us