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Think on your sins

Think on your sins

Navigating the ASA rules on greenwashing.

Anyone that knows me, will know I’m not a huge fan of the Advertising Standards Authority. 

In the creative industries they operate a little like the Spanish Inquisition. Popping up now and then, reprimanding, slapping wrists, generally ruining everyone's fun - all the while remaining apparently devoid of a sense of humour. I suppose lawyers aren’t known for their levity.

Be that as it may - the powers that be at the ASA have recently turned their iron fist to some oppression I can get behind. 

We’ve all seen the struggles of the likes of Innocent, Alpro, Pepsi, and recently, and high profile - HSBC. These are a few of the major brands who’ve had work banned on the basis of greenwashing, or falling foul of the ASA/CAP/BCAP rules. In fact, over the last year, the number of adverts banned for ‘greenwashing’ has more than tripled. Change is afoot.

From Andrew Simms of the ‘Badvertising’ campaign; “More pressure on companies due to awareness of the climate emergency means some major polluters take the easy option of trying to change their image rather than change their business. That leads to greenwash.”

We think Mr Simms is right, there’s a fair bit of ‘all talk no trousers’ flying around that the ASA are rightly calling brands out on. It’s a good fight - one worth having.

The ASA targeting false sustainability claims is a good thing. It requires marketers to be more aware of the rules, to analyse their claims, to know their businesses better, and to seek out evidence where required. It is, however, still a minefield - even for those who mean well.

Those who really mean well, are the ones we (at F+H) want to help out. So, to simplify, we’ve prepped five easy things to look out for as you plan messages and ideas:



The job of marketing is to ‘use the truth to its full advantage’ - which leaves a tricky line for marketers to toe in sustainability comms. Having said that, sustainability claims called out by the ASA rules usually fall into two camps. 

The first. Life cycle. Environmental claims must be based on the full lifecycle of the advertised product. These claims must not mislead consumers about the product's total environmental impact. Yes, electric cars emit less CO2, but they're also environmentally damaging to produce. The bigger picture is important

The second. Bolted on claims. If a product has never had a demonstrably adverse effect on the environment, marketing mustn’t imply that something has changed that improves it in that respect. For example, it’s tricky to grow ‘environmentally friendly mushrooms’. As they’re just mushrooms - they were never unsustainable in the first place. 



Irrelevance is an increasingly common reason for ads to be banned. It’s also one of the most insidious (as it’s usually not accidental).

You can often spot the use of irrelevance when advertising uses an overt message shouting about a key factor as a ‘sustainability’ message. A good example? Many products declare themselves ‘CFC-free,’ even though CFCs, or chlorofluorocarbons, which contribute to ozone depletion, have been banned since 1978. Being CFC free is just obeying the law.


Lack of substantiation.

Lack of substantiation is probably the most common reason ads are being banned right now. The ASA have been rightly hot on this because as any good scientist will tell you - ‘substantiated’ is a relative term. 

Comparative claims like ‘greener’ and ‘friendlier’ can be justified if they really are what they claim to be compared to a previous, or competitors product. The basis of that comparison however, has to be clear. Tropicana OJ, for example, might be ‘green’, but it’s no more so than Sainsbury’s ‘own brand’. Or apple juice, for that matter.



Vaguery is probably the easiest of all these sins to spot. It’s also something marketers love. 

Being specific is conspicuously rare in marketing and has been for decades - likely because of a lack of commitment - it takes commitment to be specific. No marketer wants to commit, as it opens them up to scrutiny. But that risk comes with potential reward. Being specific and single minded is the thing almost all effective marketing is based on.

When it comes to vaguery in greenwashing it just takes a little scepticism, and a critical eye to spot. We’re committed to…, we aim to…, we’re empowering x… - all red flags. The ASA decrees that the basis of environmental claims must be clear, as well as the meaning of all terms used in comms. If you don’t get it, it’s probably not just you. Await the inquisition…


Plain lying.

In our increasingly ‘post-truth’ world, this is a tricky one. As sceptics, and fans of Churchill will tell you ‘the truth is no more than a set of lies agreed upon’.

When it comes to lying, the ASA states that marketers must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists. This gives us a couple of clues as to what they mean.

First, universal claims should be used very carefully. There is always a piece of evidence that can be thrown in like a spanner in the works. Don’t deal in absolutes.

Second, there needs to be consensus around the claim from those with the expertise to support it. As ‘division of opinion’ is a relative term, it’s worth airing on the side of the body of evidence, or by referring back to surveyed consensus. Back up those claims however you can. Classic example? 9 out of 10 dentists agree…

Admittedly, it’s a tricky landscape to navigate right now. There’s a balance to be struck between sticking religiously to the rules, and using creative communication as an advantage. As a bridge between the world of sustainability, and the world of creative - it’s balance we at F+H are well practised in striking.

It’s also worth mentioning that a fear of greenwashing shouldn’t stop you making progressive claims. The ASA greenlight far more cases than they ban, and messaging about sustainability is important to your customers, investors, stakeholders, employees - as well as society at large. It’s a message that needs to be out there - for you, and for the planet.

In short - don’t fear the inquisition of the ASA, but do expect it. It’s a necessary evil, which, if we break it down - is actually an advantage to brands genuinely doing good, and a penalty for those who aren’t. That’s a good thing.

And as always - nervous about falling foul of the rules? Talk to us. We can help.