Environmental Claims Index
18.1 Transparency - Identifying The Benefit
18.2 Scientific Terminology
18.3 Factual Evidence
18.4 Generalised Claims
18.5 Limited or Qualified Claims
18.6 Claiming a False Advantage
18.7 Avoiding Ambiguity
18.8 Claims Relating to Testing on Animals
Consumers are increasingly concerned about the environmental implications of the products they buy. However, this concern is in many cases relatively un-informed, so that many viewers and listeners are likely to accept advertisers' claims at face value. It is therefore essential that claims are accurately stated, clearly explained and not likely to mislead the lay person, particularly where the claim concerns issues of a highly technical nature, as is frequently the case.
Best practice on environmental impact claims is contained in ASO 14021 and the Department for the Environment, Food and Rural Affairs’ Green Claims Code. Any decision not to follow this best practice should be justified.
18.1 Transparency – Identifying the Benefit
To help ensure that claims are understood by viewers with little or no scientific knowledge, the general nature of the benefit being claimed should be clear. There is no need for great detail, but the commercial should indicate in what respect the product is environmentally preferable.
18.2 Scientific Terminology
As a general principle, advertisements should display a sense of responsibility to the lay viewer or listener and the language used should reflect this. Scientific terminology is acceptable provided it is relevant and used in a way that can be readily understood by consumers without specialist knowledge. Technical terminology and jargon are not acceptable if used merely to 'blind with science' and to make simple claims sound impressive.
18.3 Factual Evidence
All claims relating to the environment must be supported by sound factual evidence acceptable to BACC and its technical advisers.
18.4 Generalised Claims
Any generalised claim of environmental benefit will require substantiation on a cradle to grave basis, i.e. the complete life-cycle of the product and its packaging, taking into account the effects on the environment of its raw materials, manufacture, use, disposal and any other relevant aspects. Since on this basis practically all products have some impact on the environment, categorical statements such as 'environment friendly', 'safe', or 'green' are unlikely to be appropriate to any mass-produced product.
18.5 Limited or Qualified Claims
Limited claims, which relate to one or more specific aspects of a product, may be acceptable in circumstances where more generalised ones cannot be justified. Similarly, qualified or relative claims, such as 'friendlier', may be acceptable where a product can demonstrate significant environmental advantages over competitors or an improvement to itself.
18.6 Claiming a False Advantage
Claims based on the absence of a harmful constituent or damaging effect are not acceptable when products in the category concerned do not generally contain the constituent or cause the effect. For example, 'this is a roll-on antiperspirant and contains no harmful CFCs' would be acceptable in circumstances where aerosol antiperspirants commonly did contain such chemicals. However, the claim would cease to be appropriate once CFCs had been phased out from this product category.
Claims for the absence of harmful constituents, even if they are factual, may be disallowed if the product in question contains other, equally harmful elements.
Advertisements must not falsely suggest or imply approval for a product, by, for example, an official body or environmental group, whether by words, symbols or other means.
18.7 Avoiding Ambiguity
Great care must be taken to avoid ambiguity, both in wording and the choice of visuals. If environmental images, such as pictures of wildlife, are used, they must be relevant to the claims being made and their relevance must be clear.
18.8 Claims Relating to Testing on Animals
Please refer to rule 5.2.7 of the Code which states that claims for the absence of animal testing on products are unlikely to be acceptable.
Some consumers prefer, for ethical reasons, to avoid buying products which have been tested on animals and some manufacturers have a policy of avoiding animal testing. However, even though a finished product may not have been tested on animals, it is for practical purposes very difficult to prove that none of a product's constituents have ever been tested on animals and indeed, the overwhelming likelihood is that they will have been so tested. Categorical claims such as 'Not tested on animals', or forms of words bearing the same implication, cannot therefore be accepted.
It should be borne in mind that some statements of policy on animal testing, e.g. 'We are opposed to animal testing', may be regarded as partisan in matters of public controversy and, as such, in breach of rule 4 of the Code (Political and Controversial Issues).