Michael Haydon, our UK & International Training Manager is a qualified solicitor with extensive learning and development experience in advertising compliance. Here he gives his top five tips on how UK advertisers can make sure the green claims in their TV ads don’t fall foul of the rules.
Increasingly advertisers want to include green claims in their ads as they understand it resonates with consumers. According to IBM, Institute for Business Value’s 2020 study, six in ten consumers surveyed were willing to change their shopping habits to reduce environmental impact. And, for those who say sustainability is very/extremely important, over 70 percent would pay a premium of 35 percent, on average, for brands that are sustainable and environmentally responsible.
But making claims in your ad about how green your products are, quite rightly, will attract scrutiny within a landscape of false promises and ‘greenwashing’. The UK’s ‘green sector’ attracts greater scrutiny than some, in the form of complaints, rulings and regulations.
The bread and butter of what we do at Clearcast is to help advertisers get their ads to air and keep them there. We interpret UK TV ad rules day-in day-out, so we want to offer our guidance to make sure that you get your green claims right, first time. Here are my top five tips.
1. Download, save and use CMA’s green claims code checklist
I’m a big advocate of CMA’s green claims checklist (ask anyone that attended my green training). It clearly sets out a 13-point criteria that you can use to cross-check against your claims to ensure you’re on the right track. If you’re happy to put a tick against points such as: ‘the claim is accurate and clear for all to understand’, then it will go a long way to ensuring you can answer our substantiation queries, meaning you’re more likely to get your ad on air as smoothly as possible.
2. Carry out a life cycle assessment asap
Most environmental claims require you to carry out a full ‘life cycle assessment’ (there are multiple companies online that specialize in this) and we ask that you provide it when submitting your script, as we will need to see it. This has previously been referenced by the ASA as an important reason for upheld rulings, as per BCAP Code rule 9.5. If you’d like more help understanding this requirement, we offer an in-depth analysis of it in our green training course, including a review of the ads where it was key.
3. Submit your ad to us early for consultation
If your green claims are supported by technical data, we may need to send the substantiation to one of our consultants for their expert view. Make sure you factor this into your timescales as it adds to the Clearcast feedback process. Consultants advise on issues such as: is the data robust enough to withstand challenge and if not, could the claim be amended? This last point is vital: our consultants, much like us, are advising with the intention of getting your ad to air, but crucially, ensuring it can stay there too, should it be challenged. The earlier you get your claims and substantiation to us, the better.
4. Read the ASA weekly rulings to learn from ‘banned ads’ mistakes
When creatives come up with new ideas, it may seem that they’re breaking the mould by doing something that no one has ever done before. Whilst this may be true, the reality is that many creatives and claims are similar to others that we’ve assessed in the past. Our advice to those wanting to know the ‘inside scoop’ is to read the ASA weekly rulings. Here you can find out if any of your clients, competitors or categories are having their ads banned, which will no doubt help to inform your upcoming campaigns. As well as this, I’d recommend reading the CMA scenarios. Whilst these are specific in their wording, they include familiar claims like ‘less plastic’ and ‘recyclable’ etc, which feature useful takeaways when considering their inclusion.
5. Be specific with your ad’s claims and messages
Given duration limits it can be tricky to fit all required content into a 30 second TVC. No doubt there are competing pressures from everyone involved in making the ad and of course, it needs to look great and have the right impact. With all this in mind, it’s easy to see how an ad’s main claims and messages can sometimes get muddled. This could leave the viewer unsure if a green credential is attributed to one aspect of the product or the product as a whole. Does this even matter? The answer is a resounding yes, so keep this in mind from the beginning, and weave this into the creative when making it.
For further help on all of the points above, plus more hints, tips, and advice , check out our green training option, to give you everything you need to get your green claims on air.