ESG Enforcement Tracker

The UK’s advertising regulator, the ASA, has issued a series of rulings on environmental claims identified through its ‘Active Ad Monitoring’ system, which analyses online advertisements at scale and prioritises them for human review.

On 24 June 2026, the ASA published three rulings concerning environmental marketing claims made in paid-for Google advertisements. In each case, it referred to the CAP Code and the Competition and Markets Authority (CMA) Guidance. The ASA reiterated that environmental claims must be clear and unambiguous, and that unqualified claims are liable to mislead where they omit material information. It also emphasised that absolute environmental claims require a high level of substantiation.

UNIQLO

UNIQLO promoted its fleece coats and jackets using the wording “recycled materials”. The ASA concluded that consumers would understand this as an absolute claim that all products in the range were made entirely from recycled materials. As UNIQLO could not substantiate that claim, the advertisement was found to be misleading.

Adidas

Adidas marketed “recycled running shoes […] recycled shoe range”. The ASA held that consumers were likely to interpret this as meaning that the shoes were made entirely from recycled materials. As this was not the case, the claim was considered misleading.

Calvin Klein

Calvin Klein described its women’s tops as part of “Responsibly sourced collections – Recycled, Organic & More”. The ASA considered that consumers could understand this to mean that the products in the collection were wholly made from recycled, organic, or otherwise certified materials. Because the products did not meet that standard, the advertisement was found to be misleading.

These rulings highlight the ASA’s continued scrutiny of environmental claims and its strict approach to unqualified or absolute statements.

It should be noted that ASA rulings represent determinations under the self‑regulatory CAP Code regime rather than the exercise of statutory enforcement powers. However, persistent non‑compliance may result in referral to agencies with statutory enforcement powers, including the CMA (which has the ability to take enforcement action under legislation including the Digital Markets, Competition and Consumers Act 2024).