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.
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 recycled or can be recycled, and what percentage of their product is made from recycled materials.
Ensure claims that products can be recycled are genuine
Marketers should ensure they hold suitable evidence if they wish to claim their product is recyclable. In 2014 a carpet recycling company provided examples of multiple companies recycling them in different ways to support such a claim, which the ASA considered sufficient substantiation (Carpet Recycling UK Ltd, 2 July 2014).
Similarly, when challenged about imagery in their ad featuring someone throwing a beverage bottle into a recycling bin (Lucozade Ribena Suntory Ltd, 18 August 2021), the advertiser provided evidence to demonstrate that all components of the packaging could be recycled, and the ASA concluded the ad was therefore not misleading.
The ASA has ruled that consumers will understand that “100% recyclable” means a product can potentially be recycled, not necessarily that it always will be. Marketers should nevertheless ensure that they do not exaggerate the environmental credentials of their product, for example by implying that all of a product can be recycled if only part of it can be (Rockwool Insulation Ltd, 14 October 2009).
One advertiser (Roxane UK Ltd t/a Aqua Pure, 19 January 2022) was able to demonstrate that their packaging was indeed “100% …recyclable”. However, they also claimed that the product was “100% recycled” and the ASA therefore also expected to see evidence that all components of the 500 ml bottles were made from 100% recycled material. Because the advertiser had not provided adequate substantiation on this point, the complaint was upheld in part.
Don’t exaggerate the ease with which products can be recycled
Just because components can be recycled, does not mean that the average consumer would find it easy to do so.
This is particularly the case for unusual materials such as ice packs, where claims like “widely recycled” are likely to be considered misleading if you don’t have evidence to back this up (SCA Investsments Ltd t/a Gousto, 02 December 2020).
Electricals might also require more specialist recycling services. The ASA received complaints for an ad for a electronic cigarettes featured claims “RECYCLING FOR A GREENER FUTURE”, “GreenAwareness”, the recycling symbol, and an image of single-use vapes (Imiracle (HK) Ltd t/a Elfbar, 29 November 2023). In the absence of any information about how to recycle the products, consumers were likely to expect to be able to recycle them through a wide variety of routes including through easily accessible routes such as general recycling provisions at home.
The ASA has considered various ads for artificial grass (Perfectly Green Ltd, 09 November 2022 and Easigrass (Distribution) Ltd, 27 March 2024), which stated the products were “recyclable”. They considered that consumers would understand the claim to mean that the products were easily recyclable once they had reached the end of their life cycles, using methods available to UK consumers. The ASA understood that this was not the case for either product. In the absence of any qualification to this effect, they concluded that the ads was misleading.
Don’t exaggerate the recycled content of the product
One advertiser that claimed their coffins were made of “100% recycled cardboard” was asked to change the claim because the outer edges of the cardboard were not made of recycled materials (Colourful Coffins Ltd, 14 March 2012).
A manufacturer of electric toothbrushes used the claim “100% Plant-Based Materials” (Bambooi Sustainable Enterprise Ltd t/a Bambooi, 26 October 2022), which the ASA considered misleading, in the absence of evidence to demonstrate that all the materials used in the product, including the battery and any other electrical components required for charging, were solely derived using plant matter as a raw material.
Including qualification may help, although it is important that it is presented clearly and should not contradict the headline claim (rule 3.9). Ten years on, the ASA considered an ad for a bottled beverage, which included the claim “100 RECYCLED*” (Pepsi Lipton International, 19 January 2022). The asterisk linked to a disclaimer which stated “Bottle made from recycled plastic, excludes cap and label”. They noted the text was very small and could be overlooked. Even if some had seen it, the ASA considered it was insufficient to counter the overall impression created by the ad - that all parts of the bottle were made from recycled materials – and complaints were upheld on that basis.
Marketers should be careful that they do not make claims such as “100% environmentally friendly” or "totally recyclable for zero environmental legacy" that cannot be substantiated (SEEBOARD Energy Ltd, 8 January 2003, and Euroclad Ltd, 14 June 2006).
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. Two advertisers who described their products as “low impact” and “eco-friendly”, respectively, referred to the fact that some of the materials they used could be recycled as part of their substantiation for the claim. The ASA ruled that this was insufficient to substantiate the broader implication about the environmental impact of the products across their lifecycle, and so the complaints were upheld (Howies Ltd, 23 April 2014; European Fur Breeders' Association, 21 March 2012). Advertisers should ensure that overarching claims are backed up by evidence applying to the product as a whole, rather than specific stages of its lifecycle.
See other entries on ‘Environmental claims: General’, 'Environmental claims: Biodegradable and compostable' 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 10/02/2025