Greenwashing: the ASA keeps the waters clear in cruise advertising

1. Introduction

On 3 September 2025, the Advertising Standards Authority (“ASA”) published four rulings that should prompt immediate reflection among travel and tourism businesses making environmental claims. Each ruling involved cruise promotions that leaned heavily on sustainability messaging, yet none withstood regulatory scrutiny.

The decisions serve as a clear reminder: businesses must either substantiate their environmental claims with credible evidence or avoid making them altogether. Eye-catching language around sustainability and eco-friendliness cannot be used to attract environmentally conscious consumers, unless it reflects genuine efforts to reduce environmental impact.

Nor can advertisers shift liability by saying that they were reproducing claims provided to them by a third party. 

2. Regulatory Background and Common Themes

The rulings are related to the following travel agents:

1. Barrhead Travel Service Ltd t/a BarrheadTravel promoting Celebrity Cruises;
2. Sunshine Cruise Holidays Ltd t/a Cruise 1^st  promoting MSC Cruises’ MSC World Europa;
3. TravelCircle Ltd t/a Cruise Circle promoting MSC Cruises’ MSC Euribia ; and
4. www.cruise.co.uk Ltd t/a Seascanner promoting MSC Cruises’ MSC World Europa.

These rulings were part of the ASA’s ongoing project to scrutinise “green” advertising.

2.1. Vague and Unqualified Claims Are Risky

All four ads featured broad, unqualified claims such as:

• “A Strong Focus On Sustainability And Eco-friendly Practices.” (Barrhead)
• “Powered by LNG, the world’s cleanest marine fuel.” (Sunshine)
• “showcasing the line’s commitment to environmental responsibility” (TravelCircle)
• “Eco-Friendly LNG Technology … [a] commitment to sustainability” (TravelCircle)
• “one of the most eco-friendly cruise ships afloat” (cruise.co.uk)

TravelCircle’s ad also featured hull artwork with abstract imagery of marine life and the hashtag #SaveTheSea.

Each ruling commenced with a reminder that the CAP Code requires that the basis of environmental claims must be clear, and that unqualified claims can mislead if they omit material information. In some of the rulings, the ASA also said that absolute environmental claims had to be supported by a high level of substantiation, and that environmental claims must be based on the full life cycle of the advertised product, unless the ad states otherwise.

The ASA also considered the statements from all four travel agents, and the visual cues from TravelCircle, and decided that they would be taken by consumers as absolute claims, which require a high level of substantiation. In particular, in the context of the pictured hull artwork, consumers would take TravelCircle’s ad as an absolute assurance that the ship’s fuel technology was not harmful to the environment across its full life cycle.  The cruise.co.uk and Sunshine ads amounted to claims that the advertised cruises had a lower impact on the environment than other cruises. The Barrhead ad implied that sustainability and “eco-friendly” practices were at the heart of their cruises.

The ASA observed that, in reality, cruise ships are associated with significant carbon emissions, wastewater discharge, and other forms of marine pollution. In each case, the claims lacked  clear qualification or supporting evidence. They were therefore misleading.

2.2. Responsibility Lies with the Advertiser

All four advertisers argued that the claims had been sourced from cruise operators’ materials or third-party sources – and in each case the cruise operators denied that they had had any involvement in the creation or promotion of the ads.

Unsurprisingly, the ASA rejected the advertisers’ defence, concluding that if the claim appears in their ad or on their website, they are responsible for it—regardless of its origin.

2.3. LNG Is Not a Free Pass

Three of the travel agents heavily relied in their ads on the use of liquefied natural gas (“LNG”) as an environmentally friendly option. While LNG may produce fewer pollutants than traditional marine fuels when burned, the ASA highlighted its limitations:

• LNG is still a fossil fuel.
• Its production and use involve methane slip—unburned methane emissions that contribute significantly to climate change.
• The ads failed to explain these lifecycle impacts, presenting LNG as a clean solution without qualification.

This reinforces the ASA’s position: referencing a “greener” fuel source does not exempt advertisers from the need to contextualise and substantiate environmental claims.

3. Key Points

The four ASA rulings offer important reminders for advertisers in heavily polluting industries making environmental claims.

• Vague or absolute terms such as “eco-friendly,” “sustainable,” or “green” are high risk. They must be clearly explained, qualified if necessary, and backed by robust evidence.
• Claims about cleaner fuels or technologies, including LNG, must be contextualised to avoid misleading impressions.
• Claims must relate to the full life cycle of the product or service, or, if not, the limits of the claim must be clearly explained.
• Crucially, businesses cannot rely on third-party sources to deflect responsibility: if a claim appears in their ad, they must substantiate it.

4. Conclusion

These rulings are the latest example of the ASA’s now established practice of dealing simultaneously with a number of similar breaches in the same industry. They send a clear message that greenwashing remains a major concern for the ASA.

Given that the Competition and Markets Authority (“CMA”) has also been focusing on this area, and that the CMA has recently acquired major new enforcement powers, including the ability to levy heavy fines, advertisers in polluting industries, especially the travel sector, should consider reviewing their green claims.

Please get in touch if you need further help or guidance in navigating compliance in relation to green claims.

This article was co-authored by Ioana Birsan, Trainee Solicitor