Advertisement Board’s Approach to Environmental Claims

The Advertisement Board (“Board”) reviewed numerous advertisements containing claims related to the environment in accordance with the Regulation on Commercial Advertising and Unfair Commercial Practices (“Regulation”), as well as the Guideline on Advertisements Containing Environmental Claims. The Board’s evaluation provided practical guidance for interpretation of environmental claims’ compliance to law.

• The Board examined the environmental claims in a cosmetic company’s advertisement, claiming that “they achieved a 78% reduction in CO2 emissions from 2005 to 2020, increased production volume by 37%, and made 35 facilities, including 14 factories, carbon-neutral by the end of 2019”. The Board determined that these claims were substantiated by accredited or academically recognised scientific studies, fulfilling the burden of proof under the Regulation. Therefore, the advertisements were not in violation of the applicable law.
• The Board determined that the claims in the advertisements of a personal care company’s daily hygienic pad product—such as being “biodegradable”, “environmentally friendly”, “protects the air”, and “helps reduce carbon dioxide emissions”—were not properly substantiated and concluded that these general claims were misleading and exploitative. The Board examined the claims in the baby diaper products of the same company, such as “The absorbent area is biodegradable, and the seeds inside can sprout, each baby, using thousands of diapers, will contribute to producing millions of cubic meters of oxygen as the seeds transform into plants”. The Board found that the report provided with the purpose of substantiating their claims, showing the biodegradation rate of the material used in the absorbent layer, was insufficient to support the broader claim that the entire product “decomposes in nature”. Additionally, the advertisements created the impression that every seed inside the diaper would turn into a plant, suggesting that each diaper contributes positively to the environment. The Board determined this to be misleading and exploitative of consumers' environmental sensitivity. Considering consumer habits and behaviours, the Board was of the opinion that conveying such a message without providing any warning about environmentally-friendly ways in which to dispose of diapers, misled consumers.
• The Board examined the claims “do not throw this box away for a sustainable world” and “pot-vase-storage container” along with flower visuals on the packaging of a food product. The Board concluded that these claims were misleading, as there were no actions taken by the advertiser to reduce or eliminate the environmental impact of the product, production, supply chain, or packaging. The Board concluded that assigning the responsibility of ensuring sustainability to consumers exploited their lack of knowledge and played on their environmental sensitivities, thereby violating the principles of truthfulness and honesty.
• The Board examined advertisements claiming “as environmentally conscious as you”, and ruled that these statements were misleading, as no information was provided about what they referred to, for what purpose, how they were used, or whether they pertained to the entire or a part of the product's lifecycle.
• The Board found that the claims “using 30% fewer chemicals with environmentally friendly production techniques” and “achieving 40% water preservation” for a textile company, were not properly substantiated.
• In its examination of another clothing company’s advertisement claiming “sustainable materials are used in the products in the collection”, the Board found that no information was provided about the content of the materials used in the production of the collection. As a result, the Board concluded that a perception could arise among consumers that all the products in the collection were made from these materials, which could exploit consumers' environmental sensitivity or potential lack of information.
• The Board found the advertisements of a retail company claiming “We promise to make all our packaging 100% sustainable by 2024” to be in violation of the law, as the specific brand or product group was not indicated, nor there was any direction to a website or other platform where consumers could obtain further information in regards to this ambitious claim.
• The Board examined the claims made about a paper towel product, as asserting that “it produces and transforms its own energy” and “it is produced with lower water consumption compared to standard paper production methods”, and concluded that these claims were not properly substantiated.
• In the advertisements of a washing machine, the terms “climate-friendly action” and “climate-friendly product,” were used without explanation on the environmental impact of the product’s production processes. The Board concluded that such use could lead to consumer uncertainty and exploit a lack of information, therefore found these advertisements to be misleading.

As can be understood, the Board conducted rigorous and effective supervision in 2024 to ensure compliance with the principles in the Regulation and the Guide for Advertisements Containing Environmental Claims. The Board has been particularly diligent in reviewing the fulfilment of the burden of proof. The Board is expected to continue its strict oversight of advertisements containing environmental claims.