Toyota advert deemed “irresponsible” by ASA

The Advertising Standards Authority (ASA) has recently clamped down on ads that mislead as to a product's impact on the environment, and most brands are live to the risks associated with greenwashing. Recently the ASA has gone further, and slammed Toyota's ad, which showed their SUVs driving at speed across an untarmacked, off-road landscape, as irresponsible.

What did the advert depict?

Toyota's ad, which appeared on Facebook, showed a number of their SUVs moving across a plain, causing dust to rise, before being seen on a road, driving side by side into a built-up city area. A voiceover said “One of nature's true spectacles. Toyota Hilux. Born to roam.” A poster, seen at a bus stop, read “BORN TO ROAM” with an image of two SUVs driving on a rocky slope in a savannah style landscape. In the background were around 50 identical SUVs. 

Was it irresponsible?

Adfree Cities, who believed the ads condoned behaviour that was harmful to the environment, challenged whether they were irresponsible.

Toyota argued that the ad was intended to communicate that the Hilux was meant for the toughest environments. The wording “one of nature's true spectacles” was a reference to a herd of vehicles (similar to a herd of wildebeests, and therefore they said “fantastical”) and not a reference to damage or destruction of a natural setting. Despite Toyota's commitments to positive environmental change, including the introduction of “several hybrid and electric vehicles across their range since 1997”, the ASA found the ad to be irresponsible. 

ASA findings

The ASA said that whilst it acknowledged Toyota's point that they were in part targeting specialised vehicle users, such as farmers or forest workers, who might legitimately need to use vehicles in rural or off-road environments, those scenarios were not represented in the ad, which included driving by unidentifiable categories of vehicle users in both rural and urban environments. They said that the impression given by the driving scenes and messaging in both ads was “one of driving regardless of its purpose, across off-road environments and natural ecosystems which had no regard for the environmental impact of such driving.”

The ASA found that the ads presented and condoned the use of vehicles in a manner that disregarded their impact on nature and the environment. As a result, they had “not been prepared with a sense of responsibility to society.”

What can brands learn from this?

This decision shows how strictly the ASA interprets the CAP (The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing) and BCAP (The UK Code of Broadcast Advertising) Code rules, especially in relation to the environment. Brands should learn from this and take a critical look at advertising concepts from all angles at an early stage. They should objectively consider not only whether their ad could be interpreted to be greenwashing, but also whether it could be irresponsible, harmful or misleading, bearing in mind the ASA's very narrow interpretation of its own rules.

Another take away for brands is that it is safest for ad campaigns to be either firmly realistic or, conversely, far-fetched and whimsical. To fall in the middle is to introduce risk that some consumers might understand fantastical concepts to be real. This could be misleading.

A final point to consider is that TV ads are cleared by Clearcast (a non-governmental organisation which pre-approves most British television advertising), which can lead advertisers to believe their ad is risk free. However, brands should remember that the public can complain, and the ASA can review ads which have been cleared by Clearcast, so they should not assume that clearance for airing on TV means compliance with ASA rules.

If in doubt, the Advertising & Marketing team at Freeths can provide an objective review of your proposed advertising campaigns, overlaid with extensive experience of dealing with the ASA. Contact our team for more information.


The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.

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