Who: The Committee of Advertising Practice (CAP) and the Advertising Standards Authority (ASA)
Where: United Kingdom
When: 14 August 2025
Law stated as at: 22 September 2025
What happened:
CAP has published a guidance note on how “green disposal” claims should be made in ads.
Following the ASA’s publication of independent consumer research in November 2023 on how terms like “recyclable”, “compostable” and “biodegradable” are generally understood by consumers, CAP updated its environmental guidance to reflect the key points the consumer research revealed. Some of the concerns raised by the 2023 consumer research which CAP has sought to address in its new note include:
- Robust, real‑world evidence. When referring to a product or its packaging as “recycled”, “recyclable”, “compostable”, “biodegradable” or “plastic-free”, marketers must ensure that such claims are backed by robust evidence showing that the claims are true in real world conditions. A recent study by researchers at University College London found that 60 percent of products made from plastics certified as home compostable did not fully disintegrate within a British home compost.
- Clear scope. If a green disposal term applies only to part of a product or its packaging, that must be made clear. The ASA recently ruled that a reference to a woollen carpet as “biodegradable” was misleading as it did not make clear that the term was not intended to apply to the plastic backing of the carpet.
- Disposal steps and availability. Marketers should always consider how the consumer will understand any green disposal term used in an ad. A claim that a product is “recyclable” is likely to be understood as meaning that the recycling process is widely available in the UK to consumers. Where that is not the case, it must be made clear. For example, advertisers should not claim that consumers can recycle products at home, if that is not in fact possible. In other words, it is not enough for a product simply to meet the green disposal term standard in a technical sense – it should be readily accessible to UK consumers. Claims that a product is “compostable”, when it is only intended for industrial, not domestic, compost, also need to be clarified, particularly if the product is for use at home. Marketers should also provide details of where consumers can find further information about relevant disposal locations. As for “biodegradable” claims, these should set out how the product should be disposed of to achieve that outcome. Marketers should also not forget the codes’ requirements around social responsibility – for example, they should not suggest that because a plastic is biodegradable or compostable, littering, which is illegal, is appropriate.
- Full life‑cycle thinking. Environmental claims should be based on the full life cycle of a product, including the disposal of any packaging. If harmful byproducts like greenhouse gases or microplastics are released when the product or packaging breaks down, this should be accounted for when referring to an overall environmental impact. For example, claims suggesting that a recyclable, compostable, or biodegradable product has an overall positive impact on the environment are likely to mislead if not supported by evidence.
- Timeframes matter. Where relevant, it should be disclosed how long the biodegradation or composting process takes – the longer the process, the more likely that this information is material and should not be omitted from the ad. This is particularly the case when the product is made from an unconventional plastic or non-plastic substitute that is intended to have a lower environmental impact than a traditional plastic version.
- Avoid mixed messages. If multiple green disposal terms apply to different parts of a product or its packaging, advertisers should avoid suggesting that they each apply to the whole product. CAP states that its understanding is that products or packaging made from compostable or biodegradable plastic are not generally suitable for recycling as they can contaminate the plastic recycling process. Advertisers should therefore avoid suggesting that compostable or biodegradable plastics are recyclable.
Why this matters:
Businesses making environmental disposal claims face heightened scrutiny by the ASA, not just in relation to the advertising of the product itself, but in respect of how it might be disposed of as well. Unqualified or poorly evidenced green disposal claims risk ASA rulings, reputational harm and consumer distrust. Advertisers should therefore substantiate their green disposal claims in real‑world UK conditions, qualify the scope of the claim and the availability of disposal means, provide clear disposal instructions, and consider the full life‑cycle of the product, including its packaging.
