ESG Enforcement Tracker

Key facts:

A website, www.cruisecircle.co.uk, for cruise travel agent Cruise Circle seen on 20 March 2025, included a page that focused on cruise operator MSC Cruises S.A. t/a MSC Cruises. A photo at the top of the page showed the MSC Euribia cruise ship and featured a caption that stated, “German artist […] won a competition to design the hull artwork, entitled #SaveTheSea”. The hull artwork comprised abstract imagery of marine life – including turtles, fish, an octopus and a whale. This was accompanied by statements emphasising the operator’s “commitment to environmental responsibility”. The advertisement described the ship as using “Eco-Friendly LNG Technology” and claimed it was “Powered by LNG, the cleanest marine fuel”. An NGO called Opportunity Green challenged whether the following claims were misleading: 

1. “Eco-Friendly LNG Technology”; and 
2. “LNG, the world’s cleanest marine fuel”.

Cruise Circle argued that the content on its website came from a third-party,  and that it could not monitor all externally provided material. It subsequently removed the claims from its website. MSC Cruises stated that they had no control over the form of wording used by travel agents in, among other places, their advertising, and that while they had previously shared certain promotional wording with Cruise Circle via a press release and a digital information platform, the wording in the specific claims at issue had not been supplied by them, and that earlier wording used in a 2023 press release was similar to the challenged wording, the wording used in the ad omitted some of the contextual detail present in the press release.

The ASA upheld both challenges. It found that the advertisement presented LNG technology as wholly “eco-friendly” and as the “cleanest marine fuel”, assertions that would be understood by consumers as absolute environmental claims. Under the CAP Code,  the basis of environmental claims must be clear, and absolute environmental claims require a high level of substantiation. In addition, environmental claims must reflect the full life-cycle environmental impact of the advertised product unless the advert states otherwise.

The ASA noted that LNG is a fossil fuel primarily composed of methane, and which produces CO₂, sulphur oxide, and nitrogen oxide emissions when burned. LNG production and use also involve risks of methane slip and leakage at all stages of the fuel cycle, factors that significantly contribute to climate change. Although LNG may produce lower CO₂ emissions than conventional diesel during combustion, the ASA found that the fuel still had considerable environmental impact and therefore could not reasonably be described as “eco-friendly”. In addition, no evidence had been provided to demonstrate that LNG was the least-polluting marine fuel globally.

The ASA therefore concluded that the advertisement was likely to mislead consumers, breaching CAP Code rules 3.1 on misleading advertising, 3.33 on comparisons with identifiable competitors, and rules 11.1, 11.3, and 11.4 governing environmental claims. The ASA ruled that the advertisement must not appear again in the form complained of and directed Cruise Circle to ensure that the basis of any future environmental or comparative claims is made clear. The ASA also stated that unless an advert clarified otherwise, the advertiser must hold robust evidence relating to the full life cycle of a cruise to substantiate an environmental claim.

This ruling contributes to ASA’s broader enforcement work on environmental claims, following a complaint and intelligence gathered through the regulator’s Active Ad Monitoring system.