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10 Nov, 09:53 JD Sports Christmas advert 2026: Create The New swaps festive nostalgia for young creatives 
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Agencies A to ZThree regimes govern green claims in UK advertising: CAP Code Section 11, the CMA's Green Claims Code and the DMCC Act. Here is what each requires, and the rulings that mark the line.
Last verified 4 September 2026. The word “sustainable” on its own is now enough to get a Google ad banned in the UK, and the regulator does not need a complaint to find it. This guide sets out the three regimes that govern green claims in advertising, what each requires, and the rulings against airlines, oil majors, banks, fashion houses and car brands that show where the line sits.
The ASA administers Section 11 of the CAP Code for non-broadcast ads and Section 9 of the BCAP Code for TV and radio. It rules on individual ads, orders them withdrawn and publishes the finding, and it cannot fine anyone.
The Competition and Markets Authority enforces consumer law, and its Green Claims Code, published on 20 September 2021, explains how that law applies to environmental claims. Since 6 April 2025 the Digital Markets, Competition and Consumers Act 2024 has let the CMA decide breaches itself and fine up to 10% of global turnover without going to court. On 22 January 2026 it added supply chain guidance making clear that retailers, manufacturers and distributors can all be liable for a claim, not just the brand running the ad.
The Green Claims Code has six principles: claims must be truthful and accurate; clear and unambiguous; must not omit or hide important relevant information; comparisons must be fair and meaningful; claims must consider the full life cycle; and claims must be substantiated. The CAP Code says the same things in different words.
Section 11 now has seven rules; 11.8 and 11.9 were deleted on 24 October 2025. These are the ones that generate rulings.
Two tests do most of the work. “Eco”, “sustainable” and “100% recycled” are absolute claims, so they need life-cycle evidence that the product causes no environmental harm, which almost nothing can show. And an ad can be literally true and still mislead if it omits material information about the rest of the business.
The biggest shift is in detection, not rules. The ASA’s Active Ad Monitoring system uses AI to sweep paid search and social ads by sector, and many recent fashion and airline rulings began that way rather than with a complaint. Its sweep of fashion retail produced the Nike, Lacoste and Superdry rulings on 3 December 2025 and, from ads captured that same month, the Calvin Klein, adidas and Uniqlo rulings on 24 June 2026.
Guidance has tightened too. CAP added a section on green disposal claims on 28 November 2023, requiring “recyclable”, “biodegradable” and “compostable” claims to say which parts of the product they cover and how disposal works, with proactive enforcement from 1 April 2024. CAP’s advice online entry on environmental claims was last updated on 20 January 2026.
The HSBC ruling of 19 October 2022 is the template. Two bus stop posters promoted up to $1 trillion of climate financing and 2 million trees planted in the UK. After 45 complaints, including from Adfree Cities, the ASA found the posters omitted material information: HSBC was financing significant carbon-emitting industries and would continue to through 2040. Breached: CAP 3.1, 3.3 and 11.1.
Lloyds Bank followed on 18 December 2024, upheld in part: nature partnership ads passed, but a LinkedIn post about putting the weight of its financing into renewables failed for the same omission. Barclays passed on 9 April 2025 with a magazine ad found unlikely to mislead about its overall emissions.
On 7 June 2023 the ASA ruled against Shell, Repsol and Petronas on the same day. Shell’s poster, TV and YouTube ads for lower-carbon products implied a significant proportion of its business was lower carbon, against 2021 emissions of 1,375 million tonnes of CO2 equivalent. TotalEnergies lost on 9 April 2025 for a paid X post about a renewables accelerator when 90% of its 2023 sales came from fossil fuels.
The same day as TotalEnergies, Shell won. Its TV ad, challenged by 76 complainants including Adfree Cities and Carbon Tracker, showed offshore gas beside EV charging and carried on-screen text stating that 68% of investment went to oil and gas, 23% to low-carbon energy and 9% to other products. That balance prevented a misleading impression, and it is the compliance model for any high-emitting business.
Lufthansa lost twice in 2023: a poster on 1 March for a “protecting its future” line backed by targets decades away, then on 6 December a Google ad saying “Fly more sustainably”, found by Active Ad Monitoring and faulted for not explaining that the claim rested on a paid Green Fares option. Air France-KLM and Etihad were banned the same day for “committed to protecting the environment” and “environmental advocacy”.
Virgin Atlantic’s radio ad for Flight 100, the first transatlantic flight on “100% sustainable aviation fuel”, was banned on 7 August 2024 because listeners would take the fuel to be harmless when it still produces significant life-cycle emissions. The latest airline rulings, on 15 July 2026, hit offsetting: Eurowings for a Google ad offering to “offset up to 100% of your carbon emissions per flight”, and Qatar Airways for two LinkedIn posts making the same offer.
The CMA went first. Its investigation into ASOS, Boohoo and George at Asda opened in July 2022 and closed on 27 March 2024 with formal undertakings and no finding of infringement: material claims must be specific, such as “organic” or “recycled” with the percentage shown, natural imagery such as green leaves must not imply a benefit, and key information must be prominent. The CMA wrote to the whole sector the same day.
The ASA then took the search results. On 3 December 2025 it banned Google ads from Nike (“Sustainable Materials” on tennis polos that were 75% recycled polyester), Lacoste (“Sustainable Clothing”) and Superdry (“Sustainable Style”). On 24 June 2026 it did the same to adidas for “Recycled Running Shoes” with no all-recycled range, Calvin Klein for “Responsibly sourced collections” of recycled and organic tops that were not wholly either, and Uniqlo. Partial recycled content does not support an unqualified claim.
Toyota’s “Born to Roam” Hilux campaign was banned on 22 November 2023 under rule 1.3, social responsibility, rather than Section 11. A Facebook video of a herd of Hiluxes crossing a river bed and a poster of SUVs on rocky terrain “presented and condoned” driving with no regard for its impact on nature. BMW and MG lost on 7 February 2024 for Google ads reading “Zero Emissions Cars”, a claim only true while driving that said nothing about manufacture or charging.
The pattern holds at every scale. Pepsi Lipton lost on 19 January 2022 for “100% recycled” bottles whose caps and labels were not. BrewDog and Charles Tyrwhitt both lost on 20 December 2023 for “carbon negative” and “carbon neutral” claims that did not explain the offsetting behind them.
Kit & Kin and The Cheeky Panda lost on 4 February 2026 for “eco”, “sustainable” and “biodegradable” nappies and wipes whose plastic tabs and viscose-only test data could not carry the claims.
No word is banned by name, but on the rulings these will not survive an investigation: “sustainable”, “eco” or “eco-friendly” without qualification; “100% recycled” for anything that is not; “zero emissions” without “when driving”; “carbon neutral” without explaining the offsets; a promise to offset “100%” of a flight; and any corporate green ad from a high-emitting business that does not state what proportion of the business the green activity represents.
Comparative claims are allowed if the comparison is stated and evidenced. Recyclability claims need to say which components and where. Sustainable aviation fuel can be advertised with qualifying information about its remaining emissions, and net zero targets can be stated as targets with a date. The recurring failure is putting the qualification on a landing page.
Not by rule, but in effect. The ASA treats it as an absolute claim that the product has no detrimental effect across its full life cycle, and no advertiser has yet substantiated that.
The CMA, since 6 April 2025, up to 10% of global turnover under the DMCC Act. The ASA can only ban the ad and publish the ruling.
Yes. Qatar Airways argued its LinkedIn posts targeted knowledgeable corporate buyers and lost on 15 July 2026.
For the wider framework, see our guide to UK advertising rules, and for the latest bans as they land, our running log of ASA rulings this month.
He plans, buys and reviews advertising for a living, and helps score campaigns on the site against the same five Crown Score criteria alongside other authors and contributors.
All 17 ASA rulings from October 2026, all upheld: weight-loss jab pharmacies, fake closing-down sales, AI trading and betting apps, a sexist game ad and hidden advertorials, with the CAP rules and lessons.
Since 5 January 2026, paid online ads for identifiable less healthy food are banned and TV ads face a 9pm watershed. Here is the law, the exemptions and the first ASA rulings.
CAP Section 16, BCAP Section 17, the LCCP and a voluntary industry code all govern UK gambling ads. Here is what each requires, and where the ASA is currently banning work.
