Cases / Lobbying, PR and greenwashing · United Kingdom · 2023
UK Advertising Standards Authority upholds complaints about Shell, Repsol and Petronas transition advertisements (7 June 2023)
Short record: the main facts, with sources. A full case file has not been prepared.
Nature's voice · report
Things were done in my name here. No one has measured what reached me.
Did nature suffer? Not measured.
Not on record
- The record does not name which of my species, waters, soils or forests were harmed.
On 7 June 2023 the UK Advertising Standards Authority ruled on advertisements by Shell UK Ltd, Repsol SA and Petroliam Nasional Berhad (Petronas). It found that each advertisement omitted material information and was misleading or likely to mislead.
Ads must not appear againUK ASA rulings on Shell, Repsol and Petronas advertisements
Three rulings dated 7 June 2023; Shell complaint reference G22-1170842. The ruling pages record no fine.
Three rulings dated 7 June 2023; Shell complaint reference G22-1170842. The ruling pages record no fine.
Status As of October 2026: the ASA ruled on 7 June 2023 that the Shell, Repsol and Petronas ads must not appear again in the form complained of; the ruling pages record no fine.
What?
The ASA upheld complaints about Shell, Repsol and Petronas transition advertisements and required that they not appear again in the form complained of. Advertising Standards Authority (UK)
Where?
United Kingdom (advertising regulated by the Advertising Standards Authority). Advertising Standards Authority (UK)
When?
Ruling of 7 June 2023 (Shell ads from June 2022; Repsol ad seen 2 February 2023; Petronas ad seen September 2022). Advertising Standards Authority (UK)
Who?
Gained
None on recordLost
None on recordHarmed
None on recordWhy?
The ads omitted material information: the proportion of Shell's business comprising lower-carbon products; how and when Repsol would reach net zero and the role of biofuels; Petronas' current emissions and its pathway to reducing them. Advertising Standards Authority (UK)
How?
A ruling by the Advertising Standards Authority under the CAP Code (non-broadcast) and BCAP Code (broadcast); the ruling page records the requirement that the ad(s) must not appear again in the form complained of, with no fine. Advertising Standards Authority (UK)
5 of 6 questions answered from the record · open: who
What happened
The record, in order.
On 7 June 2023 the UK Advertising Standards Authority (ASA) published three rulings on environmental advertising by oil and gas companies. The Shell ruling (complaint reference G22-1170842) covered a poster, a television ad and a YouTube video from June 2022. It records Adfree Cities as the complainant.
The ASA found that the Shell ads gave the impression that a significant proportion of Shell's business comprised lower-carbon products. Because the ads did not include information about that proportion, the ASA concluded that they "omitted material information" and "were likely to mislead" (CAP Code rules 3.1, 3.3, 11.1 for the poster and video; BCAP Code rules 3.1, 3.2, 9.2 for the television ad). A second complaint, about the renewable electricity figures in the ads (78,000 South West homes; 1.4 million UK households), was not upheld.
The Repsol ruling (A23-1185942, complainant Adfree Cities) concerned an online display ad, "At Repsol, we are developing biofuels and synthetic fuels to achieve net zero emissions". The ASA concluded that it "omitted material information and was misleading", and that the basis of the net zero claim was not clear (CAP Code rules 3.1, 3.3, 3.11, 11.1).
The Petronas ruling (A22-1169312) concerned a 60-second television ad seen in September 2022. The ASA concluded that it "omitted material information and was misleading" (BCAP Code rules 3.1, 3.2, 9.2). It noted that Petronas' operations produced 45.2 million tons of carbon dioxide and other greenhouse gases in 2021. The ruling records that it forms part of wider ASA work on environmental claims in the energy sector.
In each ruling the ASA required that the ad(s) must not appear again in the form complained of (Petronas: must not be broadcast again in its current form).
- 2023ASA rules on Shell UK Ltd (G22-1170842), Repsol SA (A23-1185942) and Petronas (A22-1169312): the ads omitted material information; the ads must not appear again in the form complained of (7 June)
How it looked
What was shown, beside what was recorded.
Shown
- Shell: a poster in Bristol ("BRISTOL is READY for Cleaner Energy"), a television ad and a YouTube video from June 2022, with figures on homes and households using renewable electricity from Shell Energy.Shell UK Ltd · Advertising Standards Authority (UK)
- Repsol: a paid online display ad on a newspaper website, seen on 2 February 2023, with leaf imagery and the text "At Repsol, we are developing biofuels and synthetic fuels to achieve net zero emissions".Repsol SA · Advertising Standards Authority (UK)
- Petronas: a 60-second television ad seen in September 2022 showing emissions reduction, renewables and recycling, with the text "Net Zero 2050".Petroliam Nasional Berhad (Petronas) · Advertising Standards Authority (UK)
Recorded
- Shell: the ASA upheld the complaint that the ads omitted material information about the proportion of Shell's business that comprised lower-carbon energy products. The complaint about the renewable electricity figures was not upheld.
- Repsol: the ASA upheld both issues (omitted material information; basis of the net zero claim not clear). Repsol told the ASA it would remove the ad, which the ASA welcomed.
- Petronas: the ASA upheld the complaint that the ad exaggerated the total environmental benefit of the company's products and services; the ad presented Petronas as already having a positive environmental impact without information on its current emissions or its pathway to reducing them.
In nature's name
What was promised in nature's name, the money that moved, and what was measured.
What was measured
Not measured
The case concerns an advertising claim. The ASA ruling records no independent measurement of any benefit to nature from the advertised product or business.
Findings on record
- Court or regulator ruling Advertising Standards Authority (UK) (2023-06-07) · G22-1170842 (Shell UK Ltd): “they omitted material information and were likely to mislead” Advertising Standards Authority (UK)
- Court or regulator ruling Advertising Standards Authority (UK) (2023-06-07) · A23-1185942 (Repsol SA): “the ad omitted material information and was misleading” Advertising Standards Authority (UK)
- Court or regulator ruling Advertising Standards Authority (UK) (2023-06-07) · A22-1169312 (Petroliam Nasional Berhad t/a Petronas): “the ad omitted material information and was misleading” Advertising Standards Authority (UK)
In court and with insurers
Every proceeding and every insurer decision on record.
Lawsuits and rulings
- 2023-06-07Claimant wonASA ruling on Shell UK Ltd transition advertisementsAdvertising Standards Authority (UK) · Regulatory · Adfree Cities → Shell UK Ltd
Upheld in part: the ads omitted material information about the proportion of Shell's business comprising lower-carbon products and were likely to mislead; the renewable electricity figures complaint was not upheld. Ads (a), (b) and (c) must not appear again in the form complained of. Advertising Standards Authority (UK)
- 2023-06-07Claimant wonASA ruling on Repsol SA online display adAdvertising Standards Authority (UK) · Regulatory · Adfree Cities → Repsol SA
Upheld: the ad omitted material information and was misleading, and the basis of the net zero claim was not clear. The ad must not appear again in the form complained of. Advertising Standards Authority (UK)
- 2023-06-07Claimant wonASA ruling on Petronas television advertisementAdvertising Standards Authority (UK) · Regulatory · Not named in the ruling (one complaint; ASA work on energy-sector environmental claims) → Petroliam Nasional Berhad (Petronas)
Upheld: the ad omitted material information about current emissions and the pathway to reducing them, and was misleading. The ad must not be broadcast again in its current form. Advertising Standards Authority (UK)
Insurers
No insurer decision on record.
What we don't know
Undisclosed, unproven, untried: recorded as data.
Nature
- Not measured Harm to nature: The record holds no measurement of harm to nature.
Record
- None on record The ruling pages record no fine and do not state whether any appeal or review followed.
- None on record The Petronas ruling does not name a complainant; it records one complaint and states that the ruling forms part of wider ASA work on environmental claims in the energy sector.
Did the harm stop?
The ASA required that the Shell ads (a), (b) and (c) and the Repsol ad must not appear again in the form complained of, and that the Petronas ad must not be broadcast again in its current form. The ruling pages do not state whether any environmental measure was affected.
Who paid?
The ruling page records no fine or payment.
Sources
Voices on record: — Company or project✓ Government and regulators— Courts— Press and investigations— Communities and civil society— Researchers
Government and regulators
- ASA Ruling on Shell UK Ltd t/a ShellAdvertising Standards Authority (UK) · 2023-06-07
- ASA Ruling on Repsol SAAdvertising Standards Authority (UK) · 2023-06-07
- ASA Ruling on Petroliam Nasional Berhad t/a PETRONASAdvertising Standards Authority (UK) · 2023-06-07
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Related matters, and cases linked to this one through the same organisations, with the role each played in both.
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