In its latest Annual report, the Advertising Standards Authority ("ASA") identified the travel sector and environmental claims amongst its focus areas for 2024. In line with that commitment, this week, the ASA published an upheld ruling against Hurtigruten UK Ltd - a cruise company trading as HX Hurtigruten Expeditions ("HX") . 

The ad appeared in the digital version of a national newspaper in March 2024.

An investigation was launched following a complaint which challenged the claim that HX were leaders in “sustainable expeditions”, in particular, challenging whether the phrase “sustainable expeditions” gave a misleading impression of the expedition's overall environmental impact. 

HX's response 

HX argued that consumers would understand the claim “sustainable expeditions” to exclude flights and only refer to its expedition cruises. This is because HX:

• Expected the word “expeditions”, in the context of the ad, would be understood by consumers as travel by land or sea;
• Used phrases like “SAIL THIS SUMMER” or “Selected Svalbard Cruises”, as well as images of a cruise ship in the ad, and; 
• Made it clear that this is an ad for a cruise company and the free flight was for a limited time only. 

XH also provided a range of examples of its sustainability efforts, which are, in fairness, quite impressive. 

ASA's decision

Despite steps taken by HX to reduce its environmental impact, the ASA considered the claim to be misleading, and therefore in breach of the CAP Code.

They said not enough evidence was provided to demonstrate that consumers understand the claim “sustainable expeditions” as a reference to travel by sea, only. The expedition began in the north of Norway, which in most cases is accessed by plane. 

The ASA also decided that the basis of the claim was not sufficiently clear, and there was not enough evidence about the full life cycle of the service (including flights). 

Our spin

Last week, we reported on an ad by Luton Airport, which was also the subject of an upheld ASA ruling, as the ASA found it was not clear enough about what was and was not taken into account as part of its claim - and in practice they had not factored in the increase in air traffic that an expanded airport would bring about.

Generally, environmental claims have to take into account the product or service's "full life cycle” - in this instance, that means having to think about and account for the way customers arrive at the cruise or expedition, especially as it was likely consumers would arrive by plane. 

There's no doubt the ASA is making it harder and harder for advertisers in the travel sector to talk about sustainable or environmentally responsible travel to anywhere outside of the country, and in particular anywhere that a flight is likely to be part of the real world journey.