Agents usually accept ad copy from suppliers in good faith and use it word for word. But the Advertising Standards Authority’s ongoing greenwashing crackdown might make some think twice in future.

Environmental claims by cruise brands and airlines have proved contentious for the ASA, with the latest transgressions seeing agents take the rap as well.

In September, Barrhead Travel, Cruise1st, Cruise Circle and Cruise.co.uk all fell foul over green claims, using text and hyperlinks from cruise brands making environmental claims the ASA said could not be substantiated.

Fuelling the argument

A bone of contention was LNG – liquefied natural gas – which some call the clean alternative to traditional marine diesel. LNG producers argue it emits no soot or smoke, releases 30% less CO2 than oil and fewer sulphur oxide emissions, something the cruise industry has leapt on.

However, LNG is typically 85-95% methane, which pressure group Transport & Environment said brought new climate issues. “LNG is primarily made up of methane – a greenhouse gas 80 times more potent than CO2 in the short term and 30 times worse in the long term.”

T&E claims methane is warming the planet faster than CO2 due to leakage from ship engines. The ASA agreed, ruling: “We understood LNG was a fossil fuel that primarily comprised methane. It produced carbon dioxide and other greenhouse gas emissions when burned.”

As well as consumer complaints, the ASA now uses artificial intelligence to monitor ads. Last year, the authority scanned 28 million ads, including cruising.

“When we identify an area to focus on, we do a horizon-scanning exercise,” said the ASA’s green project team operations manager, Justine Grimley. “Our work is probably now 50:50 reactive. We’re anticipating what’s coming down the track a bit more. This series of rulings [on LNG] came out of that work.”

Agents can easily stumble on such trip hazards. When fed marketing material, they are largely left to do their own due diligence, and it only takes one complaint to make the ASA’s charge sheet.

Joanna Lawton, marketing lead at sustainability consultancy TerraVerde, called it “a real challenge” for agents. “If they want to feature a claim in an ad, they must ask the supplier to provide evidence to support the claim, if necessary," she said.

Code of conduct

The ASA abides by the Green Claims Code, drawn up by the government’s Competition and Markets Authority. The 13-point checklist says the basis of environmental claims must be clear, and absolute claims – such as saying something is “the greenest” – “must be supported by a high level of substantiation”.

Lawton warned agents would need “a strong grasp of legislation surrounding environmental claims” to scrutinise suppliers. “Familiarising themselves with the Green Claims Code is the essential first step,” she said.

The code’s basic requirement is that when an environmental claim is made, you can prove it is true. And sustainability claims must reflect the whole life cycle of the product or service. This means calling a holiday “sustainable” when it includes a flight or cruise is likely to breach the code.

Abigail Best, managing director of Lemongrass Marketing, said the ASA had “made it clear” agents also bore responsibility for such claims. “Agents need to do more than just lift supplier text – they need to apply their own checks.”

Best recommends agents ask for evidence about cleaner fuels, reduced emissions and, in the case of cruise brands, their waste management. “Request the back-up data or recognised certifications,” she said, urging caution on pledges around LNG, biofuels or offsetting.

“Terms like ‘eco-friendly’, ‘green’ or ‘sustainable’ are high-risk without context,” Lawton continued. “For example, if a line says ‘reduced emissions’, agents should ask: compared against what baseline? Older ships? A specific year? Precision matters.”

Similarly, superlatives like “the most sustainable fleet” are almost impossible to substantiate, Best said. “Stick to factual statements like ‘this ship has advanced water treatment technology’ or ‘uses LNG, which can reduce CO2 by X% compared with heavy fuel oil’.”

She also advised checking suppliers’ hyperlinks to ensure they are up to date, and not to mention “vague future green ambitions” as current achievements.

Another trip hazard is pictures. “Greenwashing isn’t just about words,” Best said. “Overusing shots of dolphins, coral reefs or pristine beaches to imply eco-friendliness, without a direct and evidenced link to the initiative, can be misleading.”

The ASA’s Grimley stressed travel industry compliance was “largely good” and said the ASA was there to help agents via its free copy advice service. It will issue new green guidance “in the next few months”.

Clearer guidance

Abta also said it would amend current guidelines following the ASA cases “to reflect how rulings have applied to agents”.

Clia did not comment on whether it had issued guidelines to members or agents, but a spokesperson said cruise lines were “actively pursuing net zero emissions by 2050”.

Meanwhile, Grimley warns: “Lots of agents were pulling in ads from different websites and didn’t realise they would be held responsible.”

She is another who advises agents to be wary of “absolute” claims such as “eco-friendly” or “environmentally-friendly”. “Your claim must be based on the life cycle of the product,” she says.

Agents can, though, make “narrower claims”. “We do want to help people make greener choices, so it’s important people speak about things they are involved in – but not in a way that exaggerates the part they play.”

The ASA has just issued new advice on how to advertise sustainable cruising. It defines this as cruising that has invested in energy-efficient technologies, is transitioning from traditional fuel to greener alternatives, has advanced waste management systems, bans single use plastics and sources food locally.

But the ASA warns claims “that exaggerate the total environmental impact of a cruise are likely to be deemed misleading” and must consider factors like grey and black water discharge.

Lessons learnt

One brand that has learnt from experience is Intrepid Travel. In 2022, the ASA told it not to use the phrase “planet-friendly” in its ads because the tours it referred to included flights.

Hazel McGuire, Intrepid’s chief marketing officer, said the ruling “shaped the marketing language we use today, including the removal of phrases like ‘planet friendly’ from our global advertising”. “We also realised how essential it is to consider the full life cycle of a trip – not just the tour itself.”

She welcomed the ASA’s efforts to tighten the roles as “good news”, but said agents should be aware of “potential pitfalls this may bring”.

(Credit: Intrepid Travel)

“The key takeaway is to avoid making broad, unsubstantiated claims and vague language, such as ‘eco-friendly’,” she said. “Even when using supplied marketing assets, the responsibility for compliance still rests with them.”

Grimley agreed the 2023 Intrepid ruling had made the industry more cautious. “The case highlighted how even companies that have environmental measures can still make mistakes,” she said.

As for what comes next, the ASA’s gaze is now on electric vehicles, which Grimley agreed could affect car hire firms or resorts that claim they have “environmentally-friendly” electric buggies. You have been warned.