Green claims update

Key updates

ASA guidance on environmental claims in relation to beauty and cosmetics products

The ASA has published Environmental/Animal Welfare Claims Guidance to marketers, reminding them to ensure that environmental claims, eg “eco-friendly” or “kind to the planet” must be based on the complete life cycle of the product, including manufacture and disposal of the product and its packaging. There was no specific example given in the ASA’s reminder, though they noted that limited claims about a product’s “specific aspects or ingredients” may be acceptable.

CAP News – advice for cruise companies

The ASA/CAP have issued guidance on sustainable cruising to ensure advertising doesn’t come under scrutiny for greenwashing. This follows the recent four ASA rulings against cruise holiday ads which were found to have breached the CAP Code (we set out two of these rulings below). At a high level, they advise using sufficient substantiation, considering the full life cycle of product claims and making the basis of environmental claims clear.

Capgemini report

Capgemini’s Research Institute have released the fourth edition of their “A world in balance“ series. In the report, research found that 62% of consumers believe organisations are engaging in greenwashing which is an increase from the previous 52% in 2024, highlighting the growing distrust amongst consumers. Amongst other interesting insights, their research also found that in 2025, only 59% of the interviewed businesses agreed with the statement that “we follow external guidelines on responsible communication and advertising to avoid greenwashing”. Whilst this figure is up from 54% in 2024, it highlights the potential non-compliance of numerous businesses.

ASA rulings

TravelCircle Ltd t/a Cruise Circle and Sunshine Cruise Holidays Ltd t/a cruise 1st

On 3 September, the ASA upheld two complaints against travel agents Cruise Circle and cruise 1st about claims made related to cruise operator MSC Cruise. Both agents made claims suggesting that choosing MSC’s cruise services offered a “green alternative” for holidaymakers concerned about the environmental impact they cause. Cruise 1st claimed that the cruises were “Powered by LNG, the world’s cleanest marine fuel”, and Cruise Circle claimed that the cruises used “Eco-Friendly LNG Technology” and used “LNG, the world’s cleanest marine fuel”. In both complaints, the agents argued that they had taken the content from third party sources, with cruise 1st pointing to MSC’s official sources.

In Cruise Circle, MSC responded that they had no control over the form of wording travel agents used, and although they had provided a press release to Cruise Circle, the wording used in the agent’s promotion had not come from them. In cruise 1st, MSC also clarified that they did not supply the wording to the agent, which had never appeared in materials MSC used to promote the cruises.

The ASA concluded in both claims that the ads were likely to mislead, as they did not state the basis for the eco-friendly and green claims. The ASA noted in Cruise Circle that LNG was still a fossil fuel, which emitted greenhouse gases when burned so “it was, therefore, unacceptable to make an absolute claim, such as “Eco-friendly” on the basis of its use.” This was echoed in cruise 1st, where the ASA said that the agent “had not provided enough information to contextualise” claims that MSC’s cruises offered a “green alternative”.

Shell Energy UK

The ASA has ruled that a paid-for LinkedIn ad by Shell did not mislead consumers. The LinkedIn ad was a video which included the statements “What connects the Italian sun with bright engineering ideas? Our work with Baker Hughes to help meet their energy needs and decarbonise operations. Discover more at shell.com/progresstogether. Progress together.” The caption of the video stated “Discover the progress we’re making together with Baker Hughes to help reduce their emissions and decarbonise their operations in Italy. Progress happens together.”

The ASA received a complaint alleging that the ad gave a misleading impression of the overall environmental impact of Shell’s business activities.

Shell argued that the services they provide are B2B services and that the ad subject to the complaint was highlighting the support given to a corporate client. Shell emphasised that the ad was also published on LinkedIn, a professional platform and used tags and interest-based targeting tools to ensure the ad was aimed at a relevant subset of people such that the audience was a sophisticated B2B audience with relevant knowledge and experience to understand the wider context of the ad.

Although the ASA found that the targeted audience remained relatively wide and was seen by a general consumer and business audience, they broadly agreed with Shell. In particular, they found that the content of the ad was focused on business solutions which were not available to general consumers and considered the ad to be a B2B marketing communication and therefore likely to be understood as such by its audience. The ASA also found that the audience were unlikely to interpret the message as representative of Shell’s wider consumer facing activity or commentary on its own carbon transition plans. In that sense, the ad made clear that the claims were related to how they were supporting Baker Hughes, the business client, to decarbonise their operations.

Sector-specific updates

Food and drink

Leaft Foods, a New Zealand-based company specialising in plant-based protein solutions, has partnered with Lacto Japan to expand into the Asia Pacific region. Leaft extracts a protein called rubisco from leafy greens and processes into a tasteless protein powder. Per FoodNavigator Asia, Leaft CEO Ross Milne claimed that producing plant-based proteins using their method allows the company to “produce four times more protein per hectare with a 97% reduction in greenhouse gas emissions compared to dairy systems.” The company brought its first consumer product to market this year, and hopes that using rubisco in bakery, dairy alternatives and in nutritional products will build a more “climate-friendly” protein system.

Retail and consumer brands

On 9 September, the European Parliament adopted new measures to reduce waste from food and textiles in the EU. As described in the European Parliament’s press release, the new legislation includes targets to reduce waste by 10% from food processing and manufacturing, and 30% per capita from “retail, restaurants, food services and households”. The targets are to be met on a national level, compared to the waste generated per year on average between 2021 and 2023. Member states will have 20 months to transpose the directive into national legislation after it enters into force and are free to choose how to meet the targets.

Autumn 2025