Advertisment
A Twitter post on the advertisers own account stated:
“Thinking global, acting local.
We’re planting a minimum of 100,000 native trees in Ireland every year to support our natural biodiversity.
Carbon reduction is a journey we can all be a part of
Let’s put carbon into neutral.
Choose PowerPlus.”
The Tweet also included a video that stated:
“At Applegreen we think global but act local
Our journey towards a low carbon future is well under way
As we make this transition, we offer you the choice of carbon neutral driving with PowerPlus
In addition to our carbon reduction initiatives, which offset our customers emissions from driving with PowerPlus, we are also planting one native tree for every tonne of carbon that is emitted by cars using PowerPlus.
That’s a minimum of 100,000 native trees every year. Carbon reduction is a journey we can all be a part of.
Put carbon into neutral
Choose PowerPlus”
The product page on the advertisers’ website stated:
“Put carbon into neutral
Choose PowerPlus
Carbon reduction
Most of us would be lost without our cars. At the same time, we’re worried about climate change.
At Applegreen, we are aware of the part we play in creating carbon emissions. It’s a responsibility we’re taking very seriously, which is why we are determined to drive change and leave a positive legacy for future generations.
As part of our journey towards electric vehicles and a low carbon future, we’re now offering you the choice of carbon neutral driving with Applegreen PowerPlus fuel.
When you choose to fill your tank with PowerPlus, our premium fuel, not only are you benefiting from better performance and fuel efficiency, all your car’s emissions are also offset there and then.
A journey we can all be part of
The carbon credits we purchase to do this finance clean water initiatives in East Africa, allowing us to offset a minimum of 100,000 tonnes of carbon every year.
At Applegreen we aren’t just committed to carbon neutrality, we want to play our part in creating a thriving local environment for the future.
We’re also planting a tree for every tonne of carbon emitted by cars using PowerPlus. That’s a minimum of 100,000 native trees in Ireland per year. Helping to restore a healthy landscape for the future. Carbon reduction is a journey we can all be a part of.
Drive change now. Choose PowerPlus today.
Let’s put carbon into neutral.
How it works
1. Fill up with PowerPlus
Every time our customers choose to drive with PowerPlus not only are they making the better choice for their engine, they are benefitting from improved performance and efficiency, they are making a better choice for the environment.
2. We will offset your emissions
We are offering our customers the choice of carbon neutral driving with PowerPlus fuel.
When our customers choose PowerPlus, all the emissions from their driving are offset there and then.
To do this, we purchase carbon credits which finance clean water projects allowing us to offset a minimum of 100,000 tonnes of carbon every year.
3. We will plant trees for our future
More than that, every time you fill with PowerPlus you’re supporting forest creation in Ireland as we are going to plant a tree for every tonne of carbon emitted by cars using PowerPlus.
That’s a minimum of 100,000 native Irish trees every year, including Pedunculate Oak, Birch, Scots Pine, Rowan, Holly and Hazel to support Irelands biodiversity.
4. Together we are putting carbon into neutral
Carbon reduction is a journey we can all be a part of.
Choose PowerPlus today.
Let’s put carbon into neutral.
Look for PowerPlus at the pump
PowerPlus has an enhanced additive which reduces harmful emissions.
Restores your vehicle’s engine to a “like new” condition by reducing deposit build up.
Actively cleans up your vehicle’s engine as you drive.”
A paid for search engine result for the advertisers’ product stated:
“PowerPlus – Putting Carbon into neutral
Choose Applegreen PowerPlus today. Better fuel efficiency and 100% carbon neutral driving. Carbon reduction is a journey we can all be a part of.
Put Carbon Into Neutral About Drive Change
Choose carbon neutral driving Applegreen’s climate change
with Applegreen PowerPlus fuel Programme. We Take Responsibility.
Choose PowerPlus Our Partners
We are Committed to Reducing View our Natural Capital Partners
our Carbon Footprint Clear, Transparent and Accountable.”
Complaint
Two complaints were received regarding various advertisements within the campaign. One complainant objected to the Tweet and the Website while the second complainant objected to the advertisement that appeared on a search engine.
Issue 1:
A complainant considered that the Tweet, the video within the Tweet and the advertisers’ website were misleading and were greenwashing (1) as they were claiming that due to carbon offsetting (2), the advertisers’ fuel was carbon neutral (3) when the complainant considered that offsetting was both controversial and had been dismissed by climate scientists.
Issue 2:
A complainant considered that the advertisement that appeared on a search engine website was misleading as they considered that consumers could believe the product on offer was carbon free, when the product was conventional fossil fuel. They considered that the advertisement had been designed to create the illusion that what was on offer was a carbon neutral fuel when according to a climatologist, carbon neutral fuels were a myth.
Issue 3:
A complainant believed that the claim ‘carbon neutral’ was an absolute claim that should be supported by a high level of substantiation. They did not, however, believe that the ‘carbon neutral’ claim based on carbon offsetting could be substantiated. They said that the carbon offsets market was unregulated and that there was no authority who could verify the advertisers’ claims of carbon neutrality.
The complainant also said that carbon offsets could not provide carbon neutrality because they believed that the fundamental assumptions on which their claims were built were bogus. They said that most carbon offsetting projects worked by attempting to quantify how much carbon dioxide will be emitted by a particular activity (e.g. selling petrol and diesel) and then funding activity to cancel this out (e.g. planting trees in Ireland and preventing trees from being felled in Africa). They said that this relied on a form of economics based on “future value accounting” where today’s emissions could be offset by the carbon dioxide absorbed by a tree up to 100 years in the future and which meant that companies could continue to emit carbon dioxide now, with reductions happening at some point in the future.
The complainant considered that this process failed to consider key issues, firstly, that newly planted trees were a net source of carbon dioxide for more than a decade, which meant that carbon offsets had the opposite effect of what they claimed to have, instead of decreasing CO2 emissions, they contributed more CO2 into the atmosphere. The complainant said that many believed that trees would eventually become net carbon sinks based on the assumption that the trees would live long enough to become carbon sinks and would not be cut down.
Secondly, it doesn’t consider the time dimension of the climate crisis: According to the Intergovernmental Panel on Climate Change’s (IPCC ) (4) report, there are only 11 years left to make the significant changes to our economy if we’re to stand a chance of avoiding even more catastrophic climate change. The complainant said that there was no time to plant some trees in the future; for those trees to emit even more carbon for years before eventually sequestering it again and at the same time continuing to emit CO2 through fuel.
Issue 4:
A complainant considered that the term “carbon neutral driving” was ambiguous and they did not consider that the advertisers had qualified the claim in their search engine advertisement. The complainant considered that the word “driving” together with “carbon neutral” was obscuring the fact that the fuel was not a carbon neutral fuel.
Footnotes:
(1) https://dictionary.cambridge.org/dictionary/english/greenwashing – “behaviour or activities that make people believe that a company is doing more to protect the environment than it really is.”
(2) https://dictionary.cambridge.org/dictionary/english/carbon-offsetting – “the process of trying to reduce the damage caused by releasing carbon dioxide into the environment by doing other things that remove carbon dioxide, for example, by planting trees.”
(3) https://www.carbonfootprint.com/carbonneutrality.html – “Carbon Neutral – or Net Zero Carbon – is a term used to describe the state of an entity (such as a company, service, product or event), where the carbon emissions caused by them have been balanced out by funding an equivalent amount of carbon savings elsewhere in the world.”
(4) The Intergovernmental Panel on Climate Change (IPCC) is the United Nations body for assessing the science related to climate change.
Response
The advertisers said that they did not accept the suggestion that their campaign either set out to mislead consumers or had inadvertently misled consumers. They said that from the very outset of the campaign, they had acknowledged their responsibility as a fuel retailer to address their most material sustainability issues which included fuel emissions and moving towards a lower carbon future.
They said that their ‘Put carbon into neutral’ campaign was part of a wider sustainability strategy that had achieved tangible success in a number of areas including recycling, zero waste, green electricity, and the development of an infrastructure for electric vehicles (EV’s). They said that in the UK, they had the largest grid of EV fast-charging ports on the motorway network and were investing in the expansion of their Irish EV fast-charging network. They said that as was stated through the campaign, while the transition to cleaner energy was a sustainability goal they were actively working towards, in the meantime they were able to offer their customers the choice of certified Carbon Neutral Driving as a result of their accredited carbon offsetting initiatives.
Issue 1:
The advertisers stated that carbon offsetting was accepted by major global climate change organisations, including the United Nations and the World Resources Institute and that carbon neutrality was also an accepted term which was used in many places:
They said that their sustainability programme was made up of two parts.
1. Carbon Neutral® Driving certification for PowerPlus fuels: independent verification of their carbon footprint in line with The Carbon Neutral Protocol and carbon offsetting via Vita’s Gold Standard water access project in East Africa. They said that they were committed to offsetting a minimum of 100,000 tonnes of carbon dioxide equivalent each year over the next three years;
2. Native woodland creation: financing a minimum of 50ha each year of new native woodlands in Ireland following the Department of Agriculture’s Woodland Environmental Fund initiative.
They said that their Carbon Neutral driving claim was underpinned by a third party assessment conducted by a specialist carbon footprint assessment company (RSK https://rskgroup.com/) in accordance with the Greenhouse Gas Protocol, the global standard for footprint assessments (https://ghgprotocol.org/).
The advertisers said that Carbon Neutral driving was in accordance with The Carbon Neutral Protocol (https://www.carbonneutral.com/the-carbonneutral-protocol) which was used by hundreds of businesses around the world to demonstrate credible claims of carbon neutrality. They said that the Protocol was launched in 2002 and was updated annually to reflect the latest scientific and industry best practice. They said that they were offsetting emissions through an avoided deforestation project in Africa (5) and that the project was validated and verified by an independent auditor to the Gold Standard which guaranteed that the emission reductions claimed had been delivered (https://registry.goldstandard.org/projects/details/1460). They said that projects cannot sell carbon offsets until the emission reductions are delivered and have been independently audited.
The advertisers said that the carbon offset market had a well-established infrastructure to guarantee its quality-projects were verified and validated to independent third-party standards (the Gold Standard and VCS primarily) and offsets were retired through independent registries. They said that they had purchased credits through Natural Capital Partners who were a member of the industry body, the International Carbon Reduction and Offsetting Alliance (ICROA). They said that Natural Capital Partners were audited annually for compliance with the ICROA Code of Best Practice (https://www.icroa.org/The-ICROA-Code-of-Best-Practice) and that Natural Capital Partners were not allowed to sell carbon offsets from tree planting in advance of the carbon removal having occurred (i.e., the trees have grown, been counted and measured and the carbon stored been calculated in line with approved methodologies).
Issue 2:
The advertisers stated that they had taken extensive steps to ensure the effective communication of their programme via the channels that they controlled and that their programme was made up of the following two elements:
1. Carbon Neutral® Driving certification for PowerPlus fuels: independent verification of their carbon footprint in line with The Carbon Neutral Protocol and carbon offsetting via Vita’s Gold Standard water access project in East Africa. They said that they were committed to offsetting a minimum of 100,000 tonnes of carbon dioxide equivalent each year over the next three years;
2. Native woodland creation: financing a minimum of 50ha each year of new native woodlands in Ireland following the Department of Agriculture’s Woodland Environmental Fund initiative.
They said that they had taken the upmost care in all their communications to ensure that their message was clearly stating that purchasing PowerPlus fuel would offer their consumer the choice of Carbon Neutral® Driving and they provided a sample of their social media posts. They said that they had also taken steps to offer explanations to their customers as to what ‘carbon offsetting’ and ‘Carbon Neutral®Driving’ meant and what it meant for them, always striving to ensure clarity of messaging in all communications.
As above, they said that their Carbon Neutral driving claim was underpinned by a third party assessment conducted by a specialist carbon footprint assessment company (RSK https://rskgroup.com/) in accordance with the Greenhouse Gas Protocol,-the global standard for footprint assessments (https://ghgprotocol.org/).
The advertisers said that Carbon Neutral driving was in accordance with The Carbon Neutral Protocol (https://www.carbonneutral.com/the-carbonneutral-protocol) which was used by hundreds of businesses around the world to demonstrate credible claims of carbon neutrality. They said that the Protocol was launched in 2002 and was updated annually to reflect the latest scientific and industry best practice. They said that they were offsetting emissions through an avoided deforestation project in Africa (https://www.naturalcapitalpartners.com/projects/project/sub-saharan-africa-improved-water-infrastructure) and that the project was validated and verified by an independent auditor to the Gold Standard which guaranteed that the emission reductions claimed have been delivered (https://registry.goldstandard.org/projects/details/1460). They said that projects cannot sell carbon offsets until the emission reductions are delivered and have been independently audited.
The advertisers said that the carbon offset market had a well-established infrastructure to guarantee its quality-projects were verified and validated to independent third-party standards (the Gold Standard and VCS primarily) and offsets were retired through independent registries. They said that they had purchased credits through Natural Capital Partners who were a member of the industry body, the International Carbon Reduction and Offsetting Alliance (ICROA). They said that Natural Capital Partners were audited annually for compliance with the ICROA Code of Best Practice (https://www.icroa.org/The-ICROA-Code-of-Best-Practice) and that Natural Capital Partners were not allowed to sell carbon offsets from tree planting in advance of the carbon removal having occurred (i.e., the trees have grown, been counted and measured and the carbon stored been calculated in line with approved methodologies).
Issue 3:
The advertisers stated that their Carbon Neutral driving claim was underpinned by a third party assessment conducted by a specialist carbon footprint assessment company (RSK https://rskgroup.com/) in accordance with the Greenhouse Gas Protocol,-the global standard for footprint assessments (https://ghgprotocol.org/).
The advertisers said that Carbon Neutral driving was in accordance with The Carbon Neutral Protocol (https://www.carbonneutral.com/the-carbonneutral-protocol) which was used by hundreds of businesses around the world to demonstrate credible claims of carbon neutrality. They said that the Protocol was launched in 2002 and was updated annually to reflect the latest scientific and industry best practice. They said that they were offsetting emissions through an avoided deforestation project in Africa (https://www.naturalcapitalpartners.com/projects/project/sub-saharan-africa-improved-water-infrastructure) and that the project was validated and verified by an independent auditor to the Gold Standard which guaranteed that the emission reductions claimed have been delivered (https://registry.goldstandard.org/projects/details/1460). They said that projects cannot sell carbon offsets until the emission reductions are delivered and have been independently audited.
The advertisers said that the carbon offset market had a well-established infrastructure to guarantee its quality-projects were verified and validated to independent third-party standards (the Gold Standard and VCS primarily) and offsets were retired through independent registries. They said that they had purchased credits through Natural Capital Partners who were a member of the industry body, the International Carbon Reduction and Offsetting Alliance (ICROA). They said that Natural Capital Partners were audited annually for compliance with the ICROA Code of Best Practice (https://www.icroa.org/The-ICROA-Code-of-Best-Practice) and that Natural Capital Partners were not allowed to sell carbon offsets from tree planting in advance of the carbon removal having occurred (i.e. the trees have grown, been counted and measured and the carbon stored been calculated in line with approved methodologies).
Issue 4:
The advertisers stated that they had taken extensive steps to ensure the effective communication of their programme via the channels that they controlled and that their programme was made up of the following two elements:
1. Carbon Neutral® Driving certification for PowerPlus fuels: independent verification of their carbon footprint in line with The Carbon Neutral Protocol and carbon offsetting via Vita’s Gold Standard water access project in East Africa. They said that they were committed to offsetting a minimum of 100,000 tonnes of carbon dioxide equivalent each year over the next three years;
2. Native woodland creation: financing a minimum of 50ha each year of new native woodlands in Ireland following the Department of Agriculture’s Woodland Environmental Fund initiative.
They said that they had taken the upmost care in all their communications to ensure that their message was clearly stating that purchasing PowerPlus fuel would offer their consumer the choice of Carbon Neutral® Driving and they provided a sample of their social media posts.
They said that it was imperative to note that the ‘Put carbon into neutral’ campaign launched by them was in relation to launching a new sustainability initiative, not a new product. They said that as was evidenced through their website carbonneutral.applegreen.com, all social media posts, radio, video and a press release, all their communications had captured and emphasised that they were now offering their customers the choice of Carbon Neutral Driving. They said that at no point had they made any claims or indications that their fuel was carbon neutral.
Footnotes:
(5) https://www.naturalcapitalpartners.com/projects/project/sub-saharan-africa-improved-water-infrastructure
Conclusion
Complaints Not Upheld.
The Complaints Committee considered the detail of the complaint and the advertisers’ response.
Issue 1:
The Committee noted that the complainant considered that carbon offsetting was controversial and that it had been dismissed by climate scientists, whereas the advertisers had stated that carbon offsetting was accepted by organisations such as the United Nations and the World Resources Institute. The Committee reviewed all information provided and considered that it demonstrated that carbon offsetting was an accepted process. In the circumstances, they did not consider that the advertising was in breach of the Code on the grounds raised in Issue 1 of the complaint.
Issue 2:
The Committee noted the issues raised by the complainant. In this context, the Committee noted that the slogan “putting carbon into neutral” was the main headline used in the advertisement. While the Committee noted that the advertisement had stated “Better fuel efficiency and 100% carbon neutral driving”, they noted that the words “carbon neutral” were in bold while the remaining words were not, particularly the clarification that the claim of ‘carbon neutral’ was actually ‘carbon neutral driving’. While the Committee considered that the word “driving” should have been given the same prominence as “carbon neutral”, they considered that taking account of the advertisement as a whole and in context, it was clear that the benefit of the product was ‘carbon neutral driving’ and not that the fuel itself was carbon neutral. In the circumstances, the Committee did not consider that the advertising was in breach of the Code on the grounds raised in Issue 2 of the complaint.
Issue 3:
The Committee noted the concerns raised by the complainant in regard to the carbon offset market. They noted that the advertisers’ offsetting claim had been made based on a third party assessment, conducted by a carbon footprint assessment company, in accordance with the Greenhouse Gas Protocol, which was a project of the World Resources Institute. The Committee noted that the advertisers were offsetting the emissions of their PowerPlus fuel through a deforestation project in Africa, a project that had been validated and verified by an independent auditor to a standard that guaranteed that the emission reductions claimed had been delivered and that projects could not sell carbon offsets until the emission reductions were delivered and had been independently verified.
The Committee reviewed the certification provided for the project by Gold Standard, a not-for-profit organisation set up by various NGO’s including the World Wildlife Fund (WWF), and noted that the project’s status was listed as a ‘Gold Standard Certified Project’.
The Committee noted that the advertisers had engaged the services of a carbon footprint assessment company who were a member of an industry body and that the assessment company were audited annually for compliance with the industry body’s code of best practice. The Committee noted the code of practice required that “All emission reductions and removals and the project activities that generate them shall be proven to have genuinely taken place”.
The Committee considered that the advertisers had provided evidence to show that the carbon offset market was both independently verified and regulated. Given that the project used by advertisers had been certified as complying with the requirements of the industry code, the Committee did not consider that the advertising was in breach of the Code on the grounds raised in Issue 3.
Issue 4:
The Committee noted that the advertisement had referred to ‘carbon neutral driving’, not ‘carbon neutral fuel’. They noted that the search engine advertisement was served to consumers who searched using keywords that the advertisement was linked to and that the advertisement was a link to the advertisers’ website where full details of the product were provided, including a clarification of what carbon neutral driving was. While the search advertisement did not include a reference to carbon offsetting, the relevant qualifying information was only one click away, provided clarification and was not contradictory. In the circumstances they did not consider that the advertising was in breach of the Code on the grounds raised in Issue 4.
ACTION REQUIRED:
No further action required.
