Pollution claims in Transport for London advert ‘misleading’

Transport for London rapped by Advertising Standards Authority over claims made in advert for recent ULEZ consultation

Claims made in a recent Transport for London advert about the air pollution reduction benefits of the forthcoming ultra low emission zone (ULEZ) have been labelled “misleading” by the Advertising Standards Authority (ASA).

A public consultation over the London Mayor’s ULEZ plans ran between October 27 2014 and January 9 2015, and a regional press advert for the consultation featured in the Evening Standard newspaper claimed that “introducing the zone in 2020 will encourage the use of newer, cleaner vehicles to reduce vehicle pollution by half”.

However, following a four month investigation, ASA yesterday (April 9) upheld a complaint that this claim gave the impression that all air pollutants would be cut by half, whereas the evidence suggests that this related only to nitrogen oxides and nitrogen dioxide vehicle emissions and not to particulate matter or carbon dioxide emissions.

ASA highlighted as an example TfL figures which show a predicted reduction of 15% in carbon dioxide emissions in the ULEZ.

The ASA ruling states: “Because the claim related only to NO2 and NOx vehicle emissions, and excluded, for example, the figures for CO2, and total PM10 and PM2.5 emissions, we concluded that the claim was misleading.”

ASA said that on this particular point, the advertisement breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), 3.7 (Substantiation), and 11.1 (Environmental claims), although the watchdog acknowledged TfL’s intention in the advert to “avoid technical jargon so the claim would be more easily understood”.

As a result of the ruling, TfL was told by ASA “to ensure that claims about reductions in vehicle pollution referred to specific types of pollution rather than vehicle pollution as a whole”.


However, TfL said it would be appealing the ASA decision and insisted it had “provided robust evidence which substantiates the claims made in the ultra low emission zone advert”.

TfL managing director for the ULEZ, Michelle Dix, said: “Due to the complex nature of the proposals, the advert was designed to capture the most important points and avoid confusing jargon. It gave an overview of the plans, and encouraged people to visit our website for more information and to take part in a full public consultation.”

Clean Air in London

The complaint was one of three about the TfL advert made to ASA by campaign group Clean Air in London. CAL had also complained that claims in the advert relating to taxi and bus emissions, but these were both rejected by the watchdog.

Welcoming the ASA ruling, founder and director of CAL, Simon Birkett, said: “In CAL’s view, the Mayor was as much at fault as TfL in this case. The Mayor of London was shown as the most prominent signatory for the advertisement.

“It is deeply troubling that the Mayor and TfL made such a seriously misleading statement in a formal advertisement that encouraged responses to the public consultation on the Mayor’s flagship policy to tackle air pollution.

He said that supplementary information supplied by TfL in consultation documents predicted that the ULEZ would have the following pollution reduction impacts on vehicle emissions in 2020:

  • CO2 emissions 15% in the zone and 1% London-wide
  • NO2 emissions 50% in the zone and 10% in Outer London
  • NOx emissions 51% in the zone and 10% in Outer London
  • PM10 exhaust emissions 64% in the zone and 4% in Outer London
  • PM10 total emissions 9% in the zone and 0.7% London-wide
  • PM5 exhaust emissions 64% in the zone  and 4% in Outer London

Mr Birkett also called on the London Assembly’s Environment Committee to “investigate the Mayor’s governance arrangements” in relation to air quality after ASA’s ruling.

Following the end of the consultation, the Mayor of London last month confirmed final plans for the ULEZ in central London, which will come into force in September 2020 (see story).

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ASA ruling


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Roland Gilmore
Roland Gilmore
9 years ago

So, TfL think CO2 (Carbon Dioxide), CO (Carbon Monoxide) and PM (Particulate Matter) are “jargon” do they? Most school students may disagree with such high handed nonsense. TfL describe the ULEZ proposals as “complex” thus justifying their original, ridiculous “dumbing down” claim. The Mayor (if not too busy electioneering for the Conservative party) should stop this appeal to the ASA before wasting any more public money in his attempt to defend the indefensible.

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