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.
This article is about non-food products. For use of the term “organic” in the food and drink sector, see Organic Foods.
The ASA has historically upheld complaints against non-food products making ‘organic’ claims where the ad claims implicitly or explicitly that an independent standard has been met.
Beauty and Cosmetics
CAP understands that there is no UK standard for organic cosmetics, but that some independent certification bodies have created standards which require a high proportion of organic ingredients. CAP recommends that if a product meets a specific certification body standard, advertisers should consider explaining this in their advertising copy in order to avoid implying that a single, independently defined or widely-recognised UK standard exists. Advertisers should avoid describing the whole range as “organic” if only a portion of the range has been certified, or only certain ingredients are organic.
The ASA considered that consumers would understand the claim "Little Me Organics" to mean the product met an independently defined organic standard or used a high proportion of organic ingredients. Because the product used a low proportion of the organic ingredients (5%) and there was no UK standard for organic cosmetics, the ASA concluded that the ad was misleading (Boots UK Ltd, 17 October 2012).
In another example, the ASA did not accept the advertiser’s argument that "Organic Based Colour" and "Italian Organic Lifestyle" were used to communicate the advertiser’s philosophy in relation to its hair dye products. The ASA concluded that in the context of the ad, the claims would be understood to mean that the hair dye products were entirely organic and met an independently defined organic standard in the UK. As no such standards existed, the ad was misleading (Candy Harbour Ltd, 26 September 2012).
In the absence of a UK standard, the ASA may consider evidence in relation to the standards of another country. CAP would advise that advertising copy makes clear that the claim is based on a foreign standard and will, as always, need to hold evidence substantiating this claim. The ASA upheld complaints against the claims "Simply Organic" and "Naturally Organic" because there was no UK standard for organic hair products and because the advertiser did not provide sufficient documentation to show that the advertised products were certified organic by an independently defined or established US standard (Simply Organic, 28 July 2010).
More guidance for beauty and cosmetics in general can be found here.
Other products
CAP understands that describing other products, such as candles, fabric and clothing, as ‘organic’ has become increasingly common, and much like cosmetics, there is no single UK standard. Again, CAP would recommend advertisers make clear in their ads which certification they have, and avoid implying that there is a single, independently defined or widely-recognised UK standard. Additionally, when claiming something is organic, marketers must specify which element of the product is organic (such as the cotton of a t-shirt, or the wax of a candle), and should avoid implying a product as a whole is organic if it is not.
Advertisers should also take care not to contradict claims in their ads. One advertiser described a candle as being ‘organic’ whilst stating that certification companies did not allow waxes to be classed as organic because of the process of turning oil into wax, which the ASA considered to contradict rather than qualify the claim (NEOM Ltd t/a NEOM Luxury Organics, 9 January 2013).
Other environmental claims
Any advertisers wanting to make other environmental claims about their product are reminded that they need to follow the entirety of Section 11, including ensuring that the meaning of environmental claims isclear and that their claims are based on the full life cycle of the product.
Advertisers in this area are urged to read our environmental guidance at www.asa.org.uk/environment to ensure they stay within the rules.
See also Organic Foods, Organic: Pesticides, Organic: Animal Welfare, Beauty and Cosmetics: General and Environmental Claims: General