Last week the ASA upheld a complaint against Ryanair that it's stated claims in press, TV and radio adverts were inaccurate. The adverts featured claims that:

"Everybody knows that when you fly Ryanair you enjoy the lowest fares. But do you know you are travelling on the airline with Europe’s lowest emissions as well?” and “Ryanair has the lowest carbon emissions of any major airline – 66g CO2 for every passenger kilometre flown. This is because we have the youngest fleet of aircraft (avg. age 6 years, the highest load factors (97% of seats filled) and newest most fuel efficient engines”.

The complainants challenged whether the claims relating to the low CO2 emissions and that Ryanair is Europe's "Lowest Emission Airline" were misleading and whether Ryanair had sufficient evidence to substantiate the claims.

The claims were based on metrics used by Ryanair in which they calculated the grams of CO2 emissions per passenger-kilometre (a commonly used metric in the industry). However, on the ASA's assessment they considered that consumers would typically associate air travel with high levels of CO2 emissions, irrespective of the airline carrier. The comparison to other "major airlines" only included 4 others are there is no industry definition of what is considered to be a "major airline". In addition, and perhaps the nail in the coffin, was that the figures were based on efficiency rankings from 2011 - of little value for a substantiation claim in 2019.

Last week, Brinsley discussed the decision by the Guardian to ban ads from businesses involved in extracting fossil fuels (see here) and whether this could be seen as "green-washing". It seems that brands are increasingly trying to enhance their "green" credentials to play into consumer demand.

In addition to Ryanair last week, several others have fallen foul of the ASA when making environmental claims.


The German car manufacturer had a Facebook ad for its i3 electric car banned in 2017. The ad claimed that the car was "zero emissions", this was disputed on the grounds that the car incorporated a small petrol engine to maintain its charge - the ASA ruled that this was misleading.

Fischer Future Heat (FFH)

In a 2019 ad for its electric immersion heaters, FFH claimed that its product was superior to traditional water cylinders, and that they were "zero emissions". The ASA's assessment was that although the boiler itself did not directly release CO2 into the atmosphere, electricity production (in this country) is primarily as a result of burning fossil fuels - so the "zero emissions" claim is misleading. This is quite a broad response from the ASA and could apply to any electric product claiming to be "zero emissions".

Ancol Pet Products (APP)

In an ad for its biodegradable dog waste bags in 2018, APP claimed that the bags reduced the impact on the environment. However, following further research into the disposal methods of dog waste bags (i.e. via park bins), they were found to be no more beneficial than standard bags and the ad banned.


Claims made by Shell back in 2008 relating to a tar sands project and an oil refinery in Texas, were described as "sustainable". The ASA found that Shell had no data to substantiate any effective management of carbon emissions from these projects and the ad was therefore misleading.

The Shell decision in particular shows that "green-washing" is not an entirely new phenomenon, but rather that the ASA has taken a stance against such claims for some time. It is clear that any brand wishing to make claims as to its green credentials will need to have valid, up to date, data and substantiation for such claims. The FFH decision in particular seems to suggest that the fact that a product is electric (i.e. not directly emitting CO2) is insufficient to meet the ASA's standards for green or "zero emissions" claims.