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‘Confusing’ environmental claims are damaging brand reputations, says ASA research

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By Ellen Ormesher | Senior Reporter

October 20, 2022 | 7 min read

New report shows consumer confusion around meaning of ‘carbon neutral’ and ‘net zero’.

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ASA says current guidance around terminology is not sufficient

The Advertising Standards Authority (ASA) is calling for stricter regulation on the green claims made by brands after its research revealed consumers find current terminology “challenging and difficult to understand.”

The report, published today (October 20), highlights research into consumer attitudes and understanding in two priority areas: ‘carbon neutral’ and ‘net zero’ ad claims, as well as advertising claims for hybrid and electric vehicles.

The ASA recognizes that there are currently no official definitions for terms such as carbon neutral or net zero and no fixed rules for how businesses should achieve these goals. There is concern that current methods of achieving carbon neutrality/net zero are not as robust as they could be – and the aim of the research was to gauge how consumers interpreted these terms when presented in advertising.

Commenting on the findings, Miles Lockwood, director of complaints and investigations at the ASA, said: “Our research shows that there is consumer confusion about the meanings and the evidence behind carbon neutral, net zero and ad claims for hybrid and electric vehicles. It also suggests there is a need for them to be simplified and standardized. All of this signals that while the UK public buy-in to companies doing the right thing on the environment, they remain wary of ‘greenwashing’.

“We’ll act on these findings – updating guidance, sharing with government and partners, reviewing the evidence and taking enforcement action where necessary – to ensure environmental claims aren’t just hot air.”

What did the report find?

Offsetting claims, made in the context of carbon neutral and net zero, are currently the primary source of confusion and misunderstanding. Some people are unaware of what offsetting entails, think carbon neutrality implies absolute carbon reductions and feel misled when the role of offsetting in achieving carbon neutral is explained to them.

  • 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 achieving carbon neutral 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, while the potential role of offsetting, when revealed, could result in greater disappointment. Participants suggested the need for transparency is potentially greater in those sectors.

  • With hybrid and electric vehicles, the findings indicate that consumers are struggling to navigate the complex terminology and technical specifications of these vehicles and there is therefore the potential for them to be misled.

What are the next steps?

  • The ASA is to share its findings with UK government so it can consider the call for simpler, clearer and standardized definitions of carbon neutral and net zero claims, as well as claims around performance measures on hybrid and electric vehicles.

  • Guidance is to be updated before the end of 2022, ensuring consistency with Competition and Market Authority guidance in relation to carbon neutrality and net zero claims.

  • The ASA is to revisit past rulings on hybrid and electric vehicles, identifying which areas of precedent (and any guidance based on this precedent) require further consideration. The claim ’self-charging hybrid’ is an example.

  • It is to carry out a six-month monitoring period in which it will assess the impact of the updated guidance on carbon neutral and net zero claims in advertising.

  • If that monitoring concludes that carbon neutral/net zero claims are being made but the types of evidence that underpins them is questionable, it will launch a review that will seek to provide guidance about what forms of evidence are more or less likely to be acceptable to substantiate such claims in advertising

  • Such a review will take account of expert insights, policy developments in the UK and other jurisdictions and, where appropriate, consultation with interested parties.

Speaking on the research and pledges made by the ASA, Andrew Terry, a partner in the advertising team at law firm Harbottle & Lewis, said: “The latest ASA report and research is a welcome development, although implementation and resultant greater clarity in green ads will take time.

“In the last few years, the ASA has been reassuringly proactive in trying to clamp down on blatantly misleading greenwashing ads. But there are many advertisers with good intentions that come unstuck because green terminology is inconsistent or easily misunderstood.

“Having clearer and standardized definitions for concepts such as carbon neutral and net zero – as well as around electric vehicles – would aid advertisers and consumers alike. The aim is admirable, but the range of interested parties in these issues will make reaching a consensus very challenging.”

This week, HSBC was the latest brand to fall foul of the ASA guidelines, after its claims of helping clients transition to net-zero were found to be misleading.

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