Note: This advice is given by the CAP Executive about non-broadcast advertising. It does not constitute legal advice. It does not bind CAP, CAP advisory panels or the Advertising Standards Authority.
Updates to this AdviceOnline library entry will be made in due course once the review of the CAP Code, following the introduction of the unfair commercial practices (UCP) provisions in Chapter 1 of Part 4 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA), is complete. Further information on the ASA’s approach to enforcement, can be found here.
In 2021 the ASA and CAP launched a Climate Change and the Environment (CCE) project, to respond to the ongoing climate crisis and take action to ensure that environmental claims in advertising are not misleading or irresponsible. Updates about our work in this area are published here.
The project consists of several strands, including:
- Sector-specific reviews, focusing on previous ASA work on these issues, common claims in ads for these sectors, and any recent legislation or developments in understanding of their environmental impacts
- Research into consumer understanding of different types of environmental claims
- Targeted investigations, to establish new precedent and take action against advertisers who use green claims in a way that is likely to mislead or cause harm
- Updates to our existing resources, and creation of new educational material
Please see the updated CAP Advertising Guidance on The environment: misleading claims and social responsibility in advertising, and the new e-learning module that covers the rules on Climate Change and the Environment.
While this advice represents the current position, the ASA’s CCE project is actively reviewing our approach to these issues, which may lead to further rulings and updates to this guidance.
Marketers should ensure that they hold evidence to substantiate claims about the extent to which their products are biodegradable or compostable.
Ensure claims that products are biodegradable or compostable are genuine
Marketers should ensure they hold suitable evidence if they wish to claim their product is biodegradable or compostable.
In 2019, the ASA ruled that, as a minimum, to be considered as “biodegradable”, a plastic product ought to biodegrade significantly faster than its conventional plastic equivalent in the end-of-life destination that each was likely to find itself. The ASA looked at a website product page for dog was bags, which featured text which stated "Refill Poop Bag Rolls...These thick waste bags are biodegradable to lessen your dog's impact on the environment" (Ancol Pet Products Ltd, 20 November 2019). The product was made from polyethylene and a pro-oxidant additive, which made it an oxo-biodegradable plastic, which would not biodegrade when starved of oxygen. The ASA considered that consumers would expect to use dedicated dog waste bins, in order to dispose of their waste bags responsibly (to avoid the health and safety risk arising from dog waste left in the open), and that by swapping conventional plastic bags for the advertised product, they could reduce their impact on the environment. However, because the ASA understood that the most likely destination of bags left in waste bins would be incineration or landfill, where the product would not biodegrade, it meant that when consumers disposed of the product in a generally responsible manner it was no more beneficial for the environment than a conventional plastic dog waste bag.
In 2022, the ASA considered an ad for baby wipes, which claimed the “Wipes will Home compost according to European Standards EN13432” (Q River Ltd, 19 October 2022). Regarding the biodegradation of the products in home composting, the ASA considered that when the wipes were disposed of, they would often not be suitable for home composting because they would be contaminated with matter that should not be composted. They nevertheless considered evidence provided, which comprised a report relating to the viscose fibre in the wipe, which stated the fibre was fully compostable in soil conditions according to European Standards EN13432. However, they considered that because the wipe was made up of ingredients other than the viscose fibre, these could have affected the composting rate. Additionally, the report did not state the rate that the viscose fibre composted under the test conditions. They therefore considered that the test did not substantiate the claim.
Don’t exaggerate the biodegradeable content of the product
A manufacturer of electric toothbrushes used the claim “100% […] Biodegradable materials” (Bambooi Sustainable Enterprise Ltd t/a Bambooi, 26 October 2022), which the ASA considered consumers would understand as an absolute claim that all of the product’s components were biodegradable at their likely-end-of-life destination. They further claimed the products were “made from […] materials that are both recyclable and biodegradable”.
In the absence of evidence to demonstrate that all the materials used in the product, which included a battery and other electrical components required for charging, biodegradable, the ASA ruled the claims were not substantiated.
Don’t omit information material to a product’s ability to biodegrade
Further to the above, neither ad included any information about how to dispose of the product. The ASA considered that information would be important to ensuring the product reached a suitable end-of-life destination in which it could be successfully recycled or biodegraded as claimed. They considered that information was material to consumers’ understanding of the basis of the “biodegradable” and “recyclable” claims, individually or in combination. As such, they considered those environmental claims should have been accompanied by information about what they meant for the product’s disposal in order to ensure that their basis was clear.
In this ruling (Floor Design Ltd t/a Flooring by Nature, 19 February 2025), the ASA considered a website which focused on woollen carpets. They considered consumers would understand the claim “Wool carpets also biodegrade at the end of their lives” as meaning all of the wool carpets shown, including the pile and the backing, were biodegradable, and stood a reasonable chance of biodegrading, at their likely-end-of-life destination.
The advertiser said most carpets are incinerated, but that wool in a carpet would biodegrade. However, the advertiser also explained the reference to biodegradability was only intended to apply to their plastic-free products and some of their carpets used a synthetic backing. Because the ad had suggested all of the carpets, and their components, were biodegradable and had not included sufficient information about how to dispose of them to successfully biodegrade, the ASA concluded the ad was misleading.
Ensure absolute environmental claims apply to the product’s full lifecycle
The ASA has ruled that general claims about the environmental credentials of products or services may often be interpreted as absolute claims about the product’s entire lifecycle, from manufacture to disposal.
One advertiser described their “green funerals” as “[including] options for natural and biodegradable coffins made of sustainable materials including wood, willow and wool […] “ (Golden Leaves Ltd, 03 August 2022). The ASA considered that consumers would understand the claims “Explore our selection of coffins to include in an eco-friendly funeral in the UK” and “Manufactured by J C Atkinson, the UK’s premier eco-friendly coffin manufacturer, you are assured that you are purchasing quality green coffins” to mean that the coffins that they were buying would have either no impact or an overall beneficial impact on the environment. Because the claims were unqualified, they considered that consumers would understand them to be absolute claims about the total environmental benefit specifically of the coffins, over their full life cycle including burial or cremation. Because the evidence that had been provided to them did not demonstrate that there was no negative impact on the environment over the full life cycle of the coffins, they concluded that the ad was misleading.
See other entries on ‘Environmental claims: General’, 'Environmental claims: Recycling' and ‘Environmental claims: General “Green” claims’.
For further support, CAP will be hosting paid for training on 22 April 2025 to support advertisers get to grips with the rules on environmental claims in ads. Join our experts this Earth Day as they guide you through real life case studies, show you common pitfalls, and answers your questions in the live Q&A.
Updated 24/02/2025