Matt Wilson, Media and Public Affairs Manager, ASA
“Be realistic and talk transparently about your sustainability journey and where you are along it”
At the Advertising Standards Authority (ASA) our role is to make sure UK ads by legitimate businesses, across media, stick to the rules. Universal principles require ads to be responsible, truthful and to treat people fairly. While myriad products and services are advertised by businesses across sectors and industries, one common theme we’ve been monitoring is how companies are using environmental claims to promote their green credentials.
In an era in which government has set ambitious legally binding net zero targets and as the scale of the challenge to avoid catastrophic climate change becomes ever clearer, advertising and, by extension, ad regulation needs to play its part in working towards agreed climate goals. But as part of that, the ASA recognises business anxiety around the risk of making ad claims that get banned for so-called ‘greenwashing’ has been growing.
There is increasing awareness from business of just how important it is that they talk to their customers in a transparent and accurate way about environmental issues. But we also recognise that our sustained and on-going regulatory scrutiny is driving debate about how businesses should respond.
The ASA and our partner regulator the Competition and Markets Authority (CMA) have been taking a firm approach to tackling misleading green claims. We each have ambitious programmes of work which aim to tighten compliance with our rules.
As the debate around how companies should respond to the need for green transparency has developed, we’ve seen a narrative taking shape that companies face a binary choice between ‘greenwashing’ and ‘greenhushing’.
We don’t agree.
Reducing the choice that businesses have between either greenwashing or greenhushing is far too simplistic.
Impactful and informative green claims benefit consumers because they enable them to make more responsible choices. Businesses have a right to speak about the environmental credentials of their products, services, actions and ambitions. But businesses must be realistic and honest with themselves and their customers about where they are on their own sustainability journey. They need to ensure that they are communicating in a way that does not get ahead of that journey and in doing so paint a misleading or irresponsible picture.
There are usually simple, practical ways to construct claims in ads that won’t fall foul of the Advertising Codes.
Precision, using more limited claims and adding appropriate qualifications to claims can help.
If you’re in a high carbon emitting sector, adding balance when making broad aspirational claims really matters.
So, be reassured that if you’re in a business that has a high carbon footprint but are on a credible pathway to net zero or working towards other ambitious plans to shift your balance of activities, we are not going to ban your claims about those ambitions in ads so long as they tell a balanced story.
And as ever, always put yourselves in the shoes of the consumer who probably has high interest but low knowledge and understanding of the sometimes complex issues that underpin your green claims. Many consumers don’t understand what “carbon neutral” means or how it’s achieved in practice. You should assume a low level of knowledge when marketing green claims and you will need to work hard to ensure your message is not misunderstood.
Businesses are also asking us what practical assistance we can provide in navigating these issues.
The good news is that there is a lot of help out there already that businesses should be making extensive use of. And this support will further develop as our decisions continue to define when environmental claims are misleading or not. We have dedicated e-learning on environmental claims. There is comprehensive and up to date Guidance on Misleading Environmental Claims to help businesses navigate green claims. And there is our dedicated copy advice service for free, confidential, tailored advice on non-broadcast green claims.
So, take advantage of the wealth of advice and guidance.
Be realistic and talk transparently about your sustainability journey and where you are along it. Be precise, clear, balanced, honest and accurate in your ads. Don’t overclaim or assume consumers know what you know.
If you do these things, you’ll be on the right track towards greenspeaking with confidence.