Hi there,

Welcome back to The Promotion Playbook. In every edition, we unpack the strategy, execution, and legal know-how behind standout activations.

In Focus This Week: Navigating Green Claims

Consumers care about sustainability. Brands know it, and many are using environmental claims to stand out. But with growing scrutiny from regulators and the public, not all green messaging lands the right way. 

Vague or misleading green messaging can quickly lead to accusations of greenwashing, regulatory trouble, and lasting reputational harm, so regulating green claims ensures consumers can make informed decisions about their purchases.

The Evidence: Recent ASA Rulings

Shell UK Ltd

Campaign: Promoted its EV charging network and windfarm developments, alongside its traditional oil and gas business.

Complaint: 75 complaints argued the ad was misleading by overstating Shell’s environmental credentials.

Result: Not upheld – ASA ruled the ad presented a balanced view, showing both green initiatives and fossil fuel activity, with investment figures to support claims.

Barclays Bank PLC

Campaign: "POWERING a more sustainable future" campaign, run in The Economist, focused on advisory and financing in the energy sector.

Complaint: Allegations of greenwashing, suggesting the bank overstated its commitment to sustainability.

Result: Not upheld – ASA found the message was clearly aimed at a knowledgeable business audience and appropriately scoped, avoiding exaggeration.

TotalEnergies SE

Campaign: Social media ad highlighting support for renewable startup NASH Renewables.

Complaint: Accused of misleading viewers by implying renewables were the company’s main focus, without mentioning ongoing fossil fuel operations.

Result: Upheld – ASA ruled the omission of key context gave a distorted impression of the company’s overall environmental impact.

Top Takeaways for Your Own Campaigns

1. Truth is non-negotiable. Claims must be truthful, accurate, clear, and unambiguous. The CMA and ASA have both emphasised this as their top requirement.
   
   
2. Context is everything. Highlighting environmental initiatives is fine, but you must balance this with transparent communication about your overall environmental impact.
   
   
3. Consider your full product lifecycle. Environmental claims should take into account the entire environmental footprint of your product or service, not just cherry-picked green aspects.
   
   
4. Substantiation is your shield. Be prepared to back up every claim with hard evidence. Shell's success came from having robust data to support their investment figures.
   
   
5. Audience awareness matters. Different levels of disclosure may be appropriate for different audiences. However, as TotalEnergies discovered, even business-targeted communications require transparent context.

If you’re looking to ensure your prize promotions are fully compliant, tell us about your campaign here and we'll help you navigate the legal requirements with confidence.

Next week, I’ll be breaking down how to run effective promotions within the boundaries of Less Healthy Food and Drink (LHFD) Restrictions and  the Competition and Markets Authority (CMA) new fining powers, so you can stay creative without falling foul of the rules.