Updated environmental guidance: green disposal claims

Today, the ASA announced key findings from its consumer research and issue-led review on green disposal claims (i.e., ‘recyclable’/’recycled’, ‘biodegradable’, ’compostable’ and “plastic alternative” claims). To accompany this, CAP and BCAP have updated their Advertising Guidance: The environment: misleading claims and social responsibility in advertising to include, in section 3.1, guidance on the use of green disposal claims.

The updated guidance reflects key findings from the ASA research, and principles established by ASA rulings. It seeks to support advertisers in making green disposal claims which do not mislead, and sets out factors advertisers should take into account, to improve the likelihood of their ads complying with the Advertising Codes.

It clarifies that green disposal claims must be substantiated, and provides guidance on the types of information which, if included, would mean that these claims are less likely to mislead, including:

  • Which parts of a product the claim relates to.
  • Information about the disposal process, if that is likely to differ from the average consumer’s expectations.
  • Information about how long it takes for a product to fully biodegrade or compost, if that is likely to differ from the average consumer’s expectations.
  • Information about harmful by-products which are produced during the disposal process.

The ASA’s announcement states that, from January 2024, it will begin additional monitoring and carry out enforcement work to tackle ads in breach of established positions already set down in rulings; such as “100% recyclable” claims. 

After a period of grace, from 1 April 2024, the ASA will proactively investigate potentially problematic claims with a particular focus being given to: 

  • Claims that omit end of use green disposal information where such information is material to the effective and responsible disposal of the item.
  • Claims that suggest a product has multiple green disposal options where that is misleading.
  • Claims where substantiation to back up green disposal claims is not present.

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