Competition and Markets Authority Survey on Misleading Environmental Claims

The Competition and Markets Authority (CMA) is currently investigating how consumer protection legislation can be used to tackle false or misleading environmental claims in adverts. Read more about the investigation on their website.

The call for information closes on 14th December 2020.

Adfree Cities template response for members and supporters

Adfree Cities has written a template response to the ‘consumer’ survey, to help you quickly and easily make a submission.

Open the survey in a new tab – click here.

Our suggested responses are below. Adapt as you see fit, or simply copy-paste.

Questions 1-15:

Simple, mostly multiple choice questions about your personal shopping habits. Answer from your own experience.

Question 16:

Are there any products, services or sectors you particularly do or do not trust when claims are made about their environmental impact? If yes, please tell us why this is.


  • Misleading language, e.g. “Self-charging hybrid” is misleading because it obscures what proportion of a journey the car will run on fossil fuels vs. its battery ( “Clean” is misleading when the car is a hybrid (so still has a petrol engine) or even is fully electric but still causes air pollution from particulates. (
  • Imagery: Car adverts often have background imagery which includes lots of wilderness, nature or exotic locations like deserts, canyons, beaches and forests. By contrast, the reality for many urban communities is traffic congestion, lethal air pollution and a lack of space in our streets because of the number of parked cars. Car adverts are misleading, unbalanced and untrustworthy because they don’t reflect this reality.
  • Lobbying: Adverts for supposedly environmentally clean cars are difficult to take seriously if you know how much the car companies have lobbied against environmental regulations at a national, European and international level, and cheated existing regulations (e.g. the VW scandal).

I think that adverts for the dirtiest third of polluting vehicles, especially SUVs, should be prohibited altogether.


I am particularly distrustful of the big oil and gas companies (Shell, BP, Total, ExxonMobil) when they advertise their renewable products or research, because their green / renewable energy products are often a very small proportion of their total investments (e.g BP’s 4% of investments in renewables compared to 96% in fossil fuels). Fossil fuel companies should have to disclose on their adverts what proportion of their investments are in renewables vs fossil fuels. Another idea is that they should be made to display ‘Climate Health Warnings’ on their adverts (similar to tobacco packaging) so that consumers are fully aware of the harms caused by fossil fuel company adverts. These ideas were discussed in the British Medical Journal recently and also by the legal firm Client Earth. See 


I do not trust them because they use misleading language, e.g.:

  • Claims by Coca Cola that their bottles are 100% recyclable, for example, are misleading because it sends a message of “It’s okay to consume this” when actually the world cannot recycle the growing quantities of single-use plastic bottles being produced by certain industries (e.g drinks).
  • “100% biodegradable” is misleading because everything’s biodegradable eventually. It’s the amount of time it takes that’s relevant.


I do not trust adverts for flights or airports that claim to offset emissions from their flights. This is because:

  • The idea of offsetting is premised on the idea that the offsetter pays for carbon-reducing activities that would not otherwise have happened, but there are no ‘spare’ emissions – to reach zero carbon emissions in time to avert catastrophic climate change, every individual, business and government must reduce its emissions as fast as possible.
  • It is very difficult or impossible to prove that the promised carbon reduction will be delivered – for example, if offsetting pays for tree planting, what stops the trees from being cut down, or burnt down accidentally in a forest fire?
  • The time lag between instantaneous carbon emissions from a flight today, and carbon sequestration from a tree that will grow over the next 100 years, mean that the carbon dioxide in the atmosphere will continue to sharply increase before it starts to decrease. Given the late stage of the climate emergency that we are in now, this delay is dangerous.

Question 17:

Are there any particular products, services or issues relating to misleading environmental claims that have not been covered in this questionnaire that you have particular concerns about, or you think the CMA should be focusing on as part of this project?


Questions 18-21:

Diversity monitoring form: answer questions on your location, your age and ethnicity.

Adfree Cities ‘stakeholder’ response

Adfree Cities has also submitted a more detailed ‘stakeholder’ response, available on request.

Header photo: Misleading advertising with a ‘health warning’ applied. Credit: Client Earth

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