Who: The Advertising Standards Authority (ASA)
Where: United Kingdom
When: 2 December 2025
Law stated as at: 2 October 2025
What happened:
The ASA has published a report looking at environmental claims in online paid-for advertisements by major UK travel agents between August 2024 and June 2025. Using its AI-based Active Ad Monitoring system, the ASA reviewed 362,000 unique online ads appearing in paid search, display and on social media platforms.
The ASA found that fewer than 1% of those ads (319 in total) contained an environmental claim; 67% of those 319 ads (213 ads from 23 advertisers) were assessed as likely non‑compliant with the rules on environmental claims under the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code).
The monitoring exercise focused on compliance with the environmental rules in the CAP Code, including:
- Rule 11.1 which states that the basis of environmental claims must be clear and that unqualified claims could mislead if they omit material information.
- Rule 11.2 which states that the meaning of all terms used must be clear to consumers.
- Rule 11.3 which states that absolute claims must be supported by robust evidence, and comparative claims such as “greener” or “friendlier” require that the advertised product provides a total environmental benefit over the marketer’s previous product or a competitor’s product, with a clear basis of comparison.
The ASA used sector-specific and environmental keywords (for example, “green”, “planet” and “eco”) to identify ads and then referred them to specialist teams to assess likely compliance with the environmental rules section of the CAP Code. The ASA contacted advertisers and took action where it considered that the ads were likely to breach the rules.
Key issues identified
Common non-compliant claims identified by the ASA included:
- Absolute claims such as “eco-friendly” or “green” without robust evidence.
- Claims relating to sustainability and sustainable business practices.
- Sector-specific claims relating to alternative fuels, such as liquefied natural gas in cruise ships.
- Comparative claims, such as “a greener way to travel” or “less carbon than flying”.
- Claims embedded in product names, such as “eco resort” or “eco lodge”.
- Broad claims, such as “carbon conscious”.
Why this matters
The report illustrates both a low volume of environmental claims in the online travel sector and a high rate of non-compliance when such claims are made. The ASA describes the results of its findings as both a missed opportunity and evidence of advertiser uncertainty over how to communicate green claims. The report also signals continued regulatory focus on environmental claims, particularly in higher‑emission sectors like travel.
Practical compliance considerations for advertisers
Based on the ASA’s report and the requirements of the CAP Code, advertisers should:
- Be specific, not absolute: avoid broad terms such as “eco-friendly”, “green” or “sustainable” unless they can be substantiated with robust evidence.
- Explain the basis of claims: clearly state what makes a service “greener” or “less carbon intensive” (for example, route, mode of transport or specific operational changes), and ensure the comparison is fair and meaningful.
- Treat product names as claims: product names such as “eco lodge” or “eco resort” will be treated as environmental claims and must be capable of substantiation.
- Use clear, plain language: ensure that terms such as “carbon conscious” or references to alternative fuels are explained in a way that ordinary consumers will understand.
- Review all online formats: apply the same CAP Code standards across their websites, paid search ads and social media pages, including short-form ad formats.
Shereen Younis, trainee solicitor with Osborne Clarke, contributed to this article
