Who: The Advertising Standards Authority (ASA), Barrhead Travel Service t/a BarheadTravel, Sunshine Cruise Holidays Ltd t/a cruise 1st, TravelCircle Ltd t/a Cruise Circle, and www.Cruise.co.uk Ltd t/a SeaScanner
Where: United Kingdom
When: 3 September 2025
Law stated as at: 17 September 2025
What happened:
The ASA has used its active ad monitoring system to extend its focus on greenwashing to the cruise liner sector, issuing a series of rulings on the use of environmental claims within that sector.
On 3 September, four rulings were published against travel agencies that used claims promoting the apparent environmental benefits of certain cruise ships and operators:
- Barrhead Travel Service t/a BarheadTravel;
- Sunshine Cruise Holidays Ltd t/a cruise 1st;
- TravelCircle Ltd t/a Cruise Circle; and
- www.Cruise.co.uk Ltd t/a SeaScanner.
Across the decisions, various environmental claims were found to have breached the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code), including the rule that the basis of environmental claims should be made clear to consumers (rule 11.1). In particular:
‘A strong focus on sustainability and eco-friendly practices’
In the BarrheadTravel ruling, a cruise provider was promoted as having “A Strong Focus On Sustainability And Eco-friendly Practices” in an online ad. The ad did not make clear the basis or meaning of the claim and no evidence was provided to demonstrate that eco-friendly practices were at the heart of the cruise ship’s operations. The claim was therefore found to be misleading.
The ASA highlighted the significant environmental impacts of cruise travel, not only in respect of the production of high levels of CO2 and greenhouse gas emissions but also in the discharge of waste water from the ship (such as sewage and water from exhaust gas cleaning systems). This can be harmful to marine ecosystems highlighting the difficulties of making proportionate environmental claims relating to cruise ship travel similar to the scrutiny faced by airlines seeking to make environmental claims.
‘Powered by LNG, the world’s cleanest marine fuel’
Some of the ads made claims that liquefied natural gas (LNG) is a cleaner marine fuel than other forms. For example, Cruise 1st‘s website stated “Powered by LNG, the world’s cleanest marine fuel”.
The ASA found that, although LNG produced lower CO2 and greenhouse gas emissions compared with other marine fuel, it had other harmful effects such as methane slip and leakage. The amount of CO2 emissions over LNG’s lifecycle was also still significant. As this context was not explained in the ad, the ASA found that the ad exaggerated the environmental credentials of the cruise ship and was therefore likely to mislead.
Cruise Circle’s website also described LNG as “eco-friendly”. Given LNG’s substantial environmental impact, the ASA found that it was unacceptable to make an absolute claim such as “eco-friendly” about LNG.
‘One of the most eco-friendly cruise ships afloat‘
In the SeaScanner ruling, the cruise ship operator’s website claimed that its ship introduced “cutting-edge environmental technology, including an advanced LNG-powered engine, making it one of the most eco-friendly cruise ships afloat.”
SeaScanner had made efforts to substantiate the claim, hyperlinking to a web page containing details about various steps taken to improve waste management and the impact of the ship on marine life. SeaScanner also provided the ASA with a list of initiatives, which purported to reduce the ship’s overall environmental impact.
However, the ASA found the hyperlinked information insufficient to explain the claim that the ship was more eco-friendly than other operators or to put the impact of LNG into context. As such, the ad was deemed to be misleading.
Why this matters:
This series of rulings highlights the difficulty in making any environmental claims in high-emitting sectors such as the cruise industry. Making overarching claims, such as “eco-friendly”, are unlikely ever to be acceptable in this context, and making other, more specific, claims will require a high level of substantiation. General lists of environmental initiatives undertaken by a business will not, on their own, meet the required standard of substantiation for a number of different environmental claims, particularly if those initiatives do not relate to the environmental benefits being referenced.
All the rulings form part of the ASA’s ongoing Climate Change and Environment project, which it launched in 2021. The project consists of various components, including sector-specific reviews, consumer research, targeted investigations and updating existing resources. As it progresses, advertisers should expect the ASA to broaden its scope to additional sectors, particularly those that are high-carbon emitting. In addition to acting on complaints received, advertisers should remember that the ASA will also use its active ad monitoring system to identify potentially infringing ads and it has been seen to do so where green claims relating to the travel sector are concerned in particular.
