Text reads "looking for net zero?"

More Shell greenwash escapes regulation

The Advertising Standards Authority (ASA) has refused to investigate two greenwashing Shell adverts, despite assurances that a ruling against Shell in June 2023 would act as a precedent to prevent fossil fuel companies from misrepresenting their environmental credentials in future ads.

Meanwhile, the regulator has banned an advert designed to build public support for London’s Ultra Low Emission Zone, highlighting once again the limits of regulation to rein in advertising’s growing climate harms.

Weak regulation sees Shell repeatedly breaching advertising Codes

In December 2023, a LinkedIn advert for Shell Environmental Products (🤢) asked potential customers if they were “Ready for net zero?” before offering a carbon credit scheme to help businesses reach net zero, with messaging translating roughly as “we’re using bogus carbon credits so we can carry on polluting, why don’t you?”

We reported Shell’s ad to the ASA, asking the regulator to investigate on several counts of greenwashing, including that:

  • the ad failed to acknowledge Shell’s ongoing and substantial investments in fossil fuels.
  • Shell has largely abandoned their carbon credit and nature offset investment targets (on which the ads are based).
  • the oil major has sacked many of its staff working on renewables and rowed back on net zero pledges.
  • the ad is based on carbon credits which are widely proven to be ineffective at reducing emissions.
  • the terms used in the advert are unclear, including ‘net zero’ which the ASA’s own research has shown to cause confusion and mislead.

The ASA responded that they could not investigate, saying that until a Government consultation on carbon markets and carbon neutrality, they and partner organisations “are taking a consultative approach to the issue of carbon credits rather than launching individual projects or investigations in isolation”.

“Given the target business market, the specificity of the claim to the product, and our ongoing work in this area, we concluded the ad did not breach the advertising rules on the basis suggested.”

ASA, January 2023

In one small concession, the regulator asked Shell to alter the ad to include a timeframe for the net zero claim. Shell edited it to read “Carbon credits are part of Shells journey towards becoming a net zero emissions energy business by 2050.” After this edit we’ve reported the advert back to the ASA, since their guidance to advertisers require that net zero claims are based on a “verifiable strategy” to deliver them. Shell is on track to massively miss “net zero by 2050”.

Word salad by Shell in December 2023. Following ASA prompts to include a timeframe for their bogus net zero claim, Shell edited the advert to say “by 2050” and more enviro-vomit in January 2024.

In a second advert seen in “Fleet News”, Shell’s net zero claims and pro-environmental messaging failed to include any information about Shell’s fossil fuel expansion, pollution, human rights abuses, inadequate climate policy, anti-green lobbying activities and ongoing environmental crimes. The ASA refused to investigate.

Is regulation working – and is it enough?

Shell isn’t the only fossil fuel company ignoring ASA rulings to repeatedly release greenwash adverts.

In 2023, Spanish oil firm Repsol was called out twice for greenwashing, with very similar ads. At the time of Repsol’s second advert for “renewable hydrogen”, Repsol did not produce renewable hydrogen and just 0.1% of its expenditure (Capex) in 2022 was in this fuel type. Both adverts, seen in the Financial Times, were banned after being reported by Adfree Cities.

Not only is UK advertising regulation currently both untimely and ineffective, regulation can only reach the tip of the iceberg given the environmental harms caused by advertising.

The UK advertising industry was responsible for adding 32% to the emissions of every single person in the UK in 2022, according to industry group Purpose Disruptors. The ASA is limited to regulating misleading green claims or, as in the case of a recently banned Toyota SUV ad, enforcing rules relating to social responsibility. The result is that high-carbon ads are everywhere, with no grounds for challenge.

For example, analysis suggests that while fossil fuel companies and car companies greenwash prolifically, most ads for airline flights – one of the most polluting and inequitable forms of travel – completely ignore sustainability issues. The vast majority of airline adverts are outside of the regulator’s remit.

This gap between the limits of regulation and the volume of high-carbon advertising leaves us exposed every day to adverts promoting the most polluting companies and sectors, from banks like Barclays and HSBC who pour billions into fossil fuel expansion, to luxury cruise travel, airlines, massive fast food giants and fast fashion.

Royal Caribbean Cruises online video ad for the world’s largest luxury cruise liner, Icon of the Seas. The cruise ship has raised environmental concerns over leaks of highly potent methane fuel, impact on marine ecosystems and high fuel use per passenger.
A £4 million ad campaign by the UK’s Agriculture and Horticulture Development Board from 2021-2024 promotes meat and dairy, despite urgent calls for production and consumption of these carbon-intensive products to be reduced.

Advertising continues to drive up demand for fossil fuels and influence social norms, keeping us locked into a fossil fuel economy. Calls for emissions reduction and visions of a future beyond fossil fuels are drowned out by billboards, online ads and influencer posts everywhere you look. Shell and BP have been called out for specifically targeting young people, including through video games, while Shell alone was expected to spend over $250 million on advertising just in 2023.

Advertising isn’t just targeting consumers to build their brand and raise sales, although that’s an important factor in pushing up emissions – advertisers are deliberately targeting politicians licensing new oil fields and influencing investors, helping to stave off meaningful climate action.

The ASA is not only unable to act to limit the vast majority of environmentally harmful adverts, its copy advice team, which includes a paid-for service, provides “pre-publication advice on any non-broadcast ads or campaigns“. The ASA and CAP are helping polluting brands to design their adverts in a way that escapes regulatory action.

A poster on the London Underground for Boohoo fast fashion.
Fast fashion ads drive ultra-fast fashion trends with substantial negative impacts on water use, plastics pollution, fossil fuel consumption and emissions, and human rights. Emissions from fashion are expected to rise by 50% by 2023.

ULEZ ruling shows that advertising regulation is moving the deck chairs on the Titanic

The ASA recently banned an advert by the Greater London Authority for London’s Ultra Low Emission Zone. The ULEZ scheme, which has stoked up controversy among London’s motorists, is designed to reduce pollution and emissions as part of wider plans to improve London’s air quality. Adverts for the scheme aim to bridge divides and build popular support for climate and clean air measures. On the same day, the ASA banned two car adverts for using the term “zero emissions vehicle” to refer to battery electric vehicles (which genuinely represent a tailpipe emissions saving compared to fossil-powered cars) despite this term being widely used within UK legislation and policy.

While the ASA nitpicks over detail in ads aiming to help reduce pollution, the UK has set no limits on advertising for diesel SUVs, fossil fuels, airlines, fossil banks and other polluting products.

It couldn’t be clearer that advertising regulation is unfit to rein in advertising’s growing climate harms. While it’s important to ensure that green claims are trustworthy, a joined up approach and category ad bans are needed to support climate friendly policy and prevent misplaced regulation from slowing down much-needed action on clean air and the environment.

What you can do

Write to your MP: We need to stop greenwash and polluting ads at their source. This can be done through new laws that ban ads for highly polluting products and services, just like we have laws banning ads for tobacco.

You can help by writing to your MP and asking that they raise this issue in Parliament and back calls for tobacco-style legislation on high-carbon adverts. Use our template letter to write to your MP today and ask that they call time on fossil fuel advertising, for good.

A street hub ad screen showing an ad for a Burger King burger.
Burger advert in Brighton, 2023.
Image shows a bus stop ad panel advertising an electric car.
Car ad including the subtitle #biggercoolerjogger in Bristol.
KFC advert promoting unsustainable meat consumption. This type of advertising is outside of the ASA’s remit and not addressed by any policy for health or environmental protection.

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