The ASA explains that consumer understanding of “carbon neutral” and “net zero” claims in advertising is important given their increasing prevalence in ads and the potential for consumers to be misled by them. Accordingly, the ASA commissioned research into this area.

Key findings from the research include:

• 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 commonly encountered claims, but there was little consensus as to their meaning; there were calls for significant reform to simplify and standardise the definitions of such terms and for claims to be policed by an official body, such as government;
• 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 potential role of offsetting in claims was revealed, 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, when revealed, could result in greater disappointment; participant reactions suggested the need for transparency is potentially greater in those sectors; and
• participants called for more transparency about offsetting and target dates in ads.

In terms of next steps, the ASA explains that it cannot, as a matter of law, mandate definitions of “carbon neutral”, “net zero” or “offsetting”. Therefore, it must assess claims on a case-by-case basis taking account of the substantiation provided to support them. It notes, however, that in March 2022, the CMA provided the Government with environmental sustainability advice that includes a recommendation to “Create statutory definitions of commonly used environmental terms, such as biodegradable, compostable and carbon neutral”.

The ASA says that in the light of the research it will be updating its Guidance on green claims, which advises on how carbon neutral and net zero claims can be made, before the end of 2022. Such Guidance is likely to make clear that organisations making these claims must ensure that they adequately explain the basis on which they are made, even where such advertising is constrained by space or time.

Following publication of updated Guidance, the ASA says that it will carry out a six-month monitoring period in which it will assess the impact of the Guidance on carbon neutral and net zero claims in advertising. It will also gather information to assess how such claims are being substantiated.

If that monitoring concludes that carbon neutral/net zero claims are being made but the types of evidence that underpins them is questionable, the Committee of Advertising Practice will launch a review which will seek to provide guidance about what forms of evidence are more or less likely to be acceptable to substantiate such claims in advertising. That review will take account of expert insights, policy developments in the UK and other jurisdictions and, where appropriate, consultation with interested parties.

In the meantime, the ASA says that it 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. It warns that unqualified claims are likely to breach existing rules, and that it will be taking proactive action immediately to crack down on such claims. To read the ASA’s press release in full, click here.