CAP and BCAP remind readers that in 2021 the ASA’s Climate Change and the Environment project identified consumer understanding of “carbon neutral” and “net zero” claims in advertising as a priority area for research, given their increasing prevalence and the potential for consumers to be misled by them. The research that was subsequently commissioned included the following key findings:

• there is a broad spectrum of consumer engagement on environmental issues influencing their understanding of, and reaction to, environmental claims;
• carbon neutral and net zero were the most encountered claims, but there was little consensus as to their meaning; there were calls for significant reform to simplify and standardise the definitions of these terms and for claims to be policed by an official body;
• participants tended to believe that carbon neutral claims implied that an absolute reduction in carbon emissions had taken place or would take place; when the role of offsetting in claims was used in ads, this could result in consumers feeling that they had been misled;
• claims in air travel, energy and automotive advertising tended to attract more attention and the potential role of offsetting could result in greater disappointment; participant reactions suggested that the need for transparency is potentially greater in those sectors; and
• participants called for more transparency about offsetting and target dates in ads.

Due to the low level of understanding and lack of consensus in relation to the meaning of carbon neutral and net zero claims, CAP and BCAP are advising advertisers to consider the following advice, which draws on key principles of the Competition and Markets Authority’s guidance on environmental claims on goods and services and, if followed, means that claims are less likely to mislead:

• avoid using unqualified carbon neutral, net zero or similar claims; information explaining the basis for these claims helps consumers’ understanding, and should not be omitted;
• marketers should ensure that they include accurate information about whether (and the degree to which) they are actively reducing carbon emissions or are basing claims on offsetting to ensure that consumers do not wrongly assume that products or their manufacture generate no or few emissions;
• claims based on future goals relating to reaching net zero or achieving carbon neutrality should be based on a verifiable strategy to deliver them;
• where claims are based on offsetting, they should comply with the usual standards of evidence for objective claims set out in the guidance and marketers should provide information on their offsetting schemes;
• where it is necessary to include qualifying information about a claim, that information should be sufficiently close to the main aspects of the claim for consumers to be able to see it easily and consider it before they make any decision; the less prominent any qualifying information is and the further away it is from any main claim being made, the more likely the claim will mislead.

The Committees say that they will continue to monitor this area for up to six months to assess the impact of the updated Guidance. They will also gather information to assess how claims of net zero and carbon neutral are being substantiated. If that monitoring concludes that these claims are being made but the types of evidence that underpin them are questionable, the ASA will invite CAP to launch a review which would seek to provide guidance on what forms of evidence are more or less likely to be acceptable to substantiate such claims. That review will consider expert insight, policy developments both in the UK and in other jurisdictions and, where appropriate, consultation with interested parties.

In the meantime, the ASA is aware that some organisations are making carbon neutral and net zero claims which are entirely unqualified and do not explain the basis on which they are being achieved. Unqualified claims are likely to breach existing rules, and the ASA will be taking a proactive approach to address such claims. To read the Committees’ press release in full and for a link to the updated Guidance, click here.