Is the climate for environmental claims changing?

We’ve all seen the news. Greek islands on fire. Record temperatures in Southern Europe. Protesters demanding action on climate change. It’s no surprise that businesses taking positive action want to tell consumers what steps they’re taking to be environmentally responsible.

We’ve seen a big uptick in the number of advertisers making environmental claims. Whether the ad promotes compostable packaging, energy efficient heating products, tree planting schemes or farming techniques aimed at increasing biodiversity, we need to be sure that advertising messages on commercial radio are honest and truthful with customers. That means we need to consider not just the specific initiative mentioned in an ad, but also the overall environmental credentials of our advertisers’ products and services. Sometimes this can be difficult to decide. For instance, if an advertiser’s products are promoted as being made from 100% recycled plastic but the production process necessitates the use of more materials, energy and water than the conventional alternative, how can we determine whether or not the product offers an overall environmental benefit compared to conventional products in the same market?

In addition to seeking advice from our environmental consultant, one of the tools we use is the Advertising Standards Authority’s “Guidance on Misleading Environmental Claims and Social Responsibility” (updated recently and is available to download here), which operates in tandem with the Competition and Market’s Authority’s guidance “Making Environmental Claims on Goods and Services”.

The advertising codes state that “The basis of environmental claims must be clear. Unqualified claims could mislead if they omit significant information”. This means that when approving an advertisement, we need to consider the knowledge and the understanding of a general, non-expert audience.

The ASA guidance explains that environmental claims are likely to mislead if the basis of the claim is not clear and that unqualified claims could mislead if they omit “significant information”. How do we determine whether an ad omits something the ASA would consider significant? The guidance goes on to explain that the ASA has ruled against ads which made positive environmental claims about specific aspects of a business when that business remained responsible for a significant amount of environmental harm. That means that we need to consider an advertiser’s wider environmental impact and whether claims about their environmentally positive initiatives arguably exaggerate environmentally positive actions or misleadingly underplay their overall negative environmental impact.

When we’re reviewing a radio ad that makes claims of a specific or overall environmental benefit to a particular policy or process, we’ll therefore typically ask advertisers to read the ASA’s guidance and explain to us, with evidence and reference to this guidance, how their messaging complies with this advice.

If you have any queries on this or any other issue, you can reach us at clearance@radiocentre.org