Last week saw both Recycle Week 2021 and the publication of the Competition and Markets Authority’s (CMA) guidance on environmental claims on goods and services. Climate change and the environment are currently high the Advertising Standards Authority (ASA) and Committee of Advertising Practice (CAP) agenda, so it is more paramount than ever that advertisers familiarise themselves with the CAP guidance in this area. Below we have summarised some key features of CAP’s guidance, and the ASA approach to, recycling claims.
Claims about recycling and recyclability must be supported by evidence
Marketers should ensure that they only describe products as being “recyclable” if they are actually capable of being recycled. Marketers should ensure they hold suitable evidence in substantiation of the recycling claims they make. And importantly, they should hold that evidence prior to the publication of any ad making such a claim. When making “recyclable” claims, marketers should not omit any salient information; for example, if a product can only be recycled in very limited circumstances. On a similar note, claims should not give the impression that a marketer’s products are greener or more sustainable than they really are. For example, focussing on claims that represent a minor positive impact, when their main business produces significant negative effects.
On a slightly different tack, marketers should also not make claims about the amount they recycle unless they hold evidence to that effect. The ASA ruled not to uphold a complaint made about an advertiser who claimed “94% of Waste Diverted from Landfill” after they were provided with robust evidence supporting that claim.
Claims should not exaggerate the recyclability of a product
Marketers must not exaggerate the recyclability of a product or its packaging. Consumers are increasingly conscious of trying to make an effort to recycle the packaging and goods they consume. To this end, marketers will want to be cautious about making claims exaggerating the environmental credentials of a product that is not widely recyclable. The ASA has previously upheld complaints about claims that packaging “100% recyclable” when it contained a plastic element that was not widely recyclable.
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