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Keeping you in-the-know on environmental, social and governance developments

In the final weeks of 2023, UK government agencies honed in on misleading statements and green claims. The Advertising Standard’s Agency (ASA) pulled multiple ads from airlines and the Competition and Markets Authority opened an investigation into Unilever, which we wrote about here. Linklaters wrote a summary of the UK’s actions and provided the following tips from current UK green marketing guidance:

  • “The need to be able to substantiate and evidence your environmental claims, particularly in relation to absolute environmental claims such as ‘sustainable’ or ‘environmentally friendly’ which need a high level of substantiation.
  • The need to give a balanced account of where your business is on its decarbonisation and sustainability journey, especially if you are in a high-carbon emitting sector. The significance of a business’ lower carbon activities and adverts which focus on specific net zero initiatives should explain where the initiatives fit in the business’ wider net zero plan.
  • The less prominent any qualifying information is, and the further away it is from any main claim being made, the more likely it is the claim will mislead consumers. The information does not have to dominate ads, but it must not be hidden away.
  • Always put yourselves in the shoes of the consumer and assume a low level of knowledge when marketing green claims.
  • Go back to basics: claims should be truthful, accurate, clear and unambiguous.”

While the airlines targeted by the ASA only had ads pulled for being misleading, the article mentions that later this year the CMA will gain broad enforcement powers over misleading green claims. Under the new system, the CMA will be allowed to find companies up to 10% of their global turnover if their conduct is deemed to mislead customers about their sustainability impacts.

The UK has been a leader in censoring misleading green advertisements and the increased enforcement powers of the CMA indicate that the government will continue to pursue this objective. At the same time, the EU is currently working to finalize their new Green Claims Directive. Here in the US, the FTC continues to update its Green Guides for Environmental Marketing. Where green claims in the past may have allowed for some exaggeration or omitting critical details, we’re moving to a regulatory landscape that holds green claims to a higher standard. Companies should update practices around their sustainability marketing and telling the whole story about their sustainability impacts, or face significant new regulatory enforcement risk.

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The Editor

Zachary Barlow is a licensed attorney. He earned his JD from the University of Mississippi and has a bachelor’s in Public Policy Leadership. He practiced law at a mid-size firm and handled a wide variety of cases. During this time he assisted in overseeing compliance of a public entity and litigated contract disputes, gaining experience both in and outside of the courtroom. Zachary currently assists the editorial team by providing research and creating content on a spectrum of ESG… View Profile