Picture two adverts. A bank: we are planting trees on the road to net zero. A fuel company: we are building the clean energy of the future. Both are claims. A claim is a sentence somebody said about themselves. Whether anybody checked it is a separate fact, and this lesson is about that fact.
An auditorreads the count
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The advert referee
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The market referee
Three kinds of checker. An outside auditor, paid to read the count: PwC read Heathrow's 2024 and 2025 figures and gave limited assurance, which means nothing came to its attention, a lower bar than a full audit. A referee for adverts: in the UK, the Advertising Standards Authority. A referee for the market: the Competition and Markets Authority.
The count
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PwClimited assurance
Heathrow's count was read by PwC and given limited assurance. What does limited mean?
They tested selected numbers and nothing came to their attention. It is not a full audit of every tonne.
Right. Limited assurance is a real check with a stated edge. It says the count was looked at by someone outside, and it says how far they looked.
They counted every plane themselves.
Not yet. An auditor reads the count and tests parts of it against records. It does not re-count the world. Heathrow's contractor did the sum; PwC checked it.
They found it wrong.
Not yet. A count found wrong gets no assurance. Limited describes how deep the check went, not a verdict against it.
HSBC, Oct 2022misleading
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Shell, Repsol, Petronas, June 2023misleading
The advert referee at work. In October 2022 the ASA ruled HSBC's posters on tree planting and net-zero finance misleading: they left out that the bank financed heavy emitters too. In June 2023 it ruled against Shell, Repsol and Petronas: the clean part shown, the oil and gas left out. It cannot fine; the advert must not run again.
Each card is a claim about carbon. Was it checked by somebody outside, or only said?
One card at a time. Tap the pile it belongs to.
Card 1 of 6
Heathrow's 2025 tonnes, read by PwC
HSBC's 2021 poster: we are planting trees
The UK's cut since 1990, published by the government's own statisticians with its method
A T-shirt label: eco-friendly
Shell's 2022 advert: the UK is ready for cleaner energy
An Austrian airline's 2022 advert: fly CO2-neutral
Heathrow's 2025 tonnes, read by PwC → Checked
Not yet. Checked. An outside firm read the count and put its name to limited assurance. The edge of the check is stated; the check happened.
HSBC's 2021 poster: we are planting trees → Only said
Not yet. Only said, and then checked by a referee who found it misleading. A claim in an advert is the company's sentence until someone outside reads it.
The UK's cut since 1990, published by the government's own statisticians with its method → Checked
Not yet. Checked, in the sense that counts: a count done by a stated method, published with it, and open for anyone to redo. A claim with its sum attached.
A T-shirt label: eco-friendly → Only said
Not yet. Only said. No count, no method, no checker. From September 2026 the EU will not allow the word unless a recognised top standard backs it.
Shell's 2022 advert: the UK is ready for cleaner energy → Only said
Not yet. Only said, and ruled misleading in June 2023 for leaving out what the rest of the business was.
An Austrian airline's 2022 advert: fly CO2-neutral → Only said
Not yet. Only said. A court found it misleading in 2023: only about 0.4 in 100 of the fuel was the plant-based kind the advert leaned on.
2Checked
vsvs
4Only said
Right. Two checked, four only said. The two checked ones have a count and a method or a checker's name attached. The four said ones are sentences, and three of the four were later found misleading by someone who read them.
4 of 10
in 10 green claims that could mislead, 2020 sweep
The market referee. In November 2020 regulators in several countries swept 1,095 company websites. Of the first 495 they read, about 40 in 100 of the green claims could mislead. In September 2021 the UK's CMA published a Green Claims Code. From September 2026 the EU bans words like eco-friendly unless the product meets a recognised top environmental standard.
Picture one cotton T-shirt. Move where the edge of its carbon count is drawn. The numbers are made up to show the shape; published studies of a real shirt land anywhere from under 4 to over 10 kilograms, for this reason.
Counted so far3 kg of CO2, made up
The widest count11 kg of CO2, made up
What the count includes: Making it
Making it: the factory's energy, sewing and dyeing. A small number, and a true one, as far as it goes.
Counted so far3.5 kg of CO2, made up
The widest count11 kg of CO2, made up
What the count includes: Plus shipping it
Plus the ship and the lorry. A little more.
Counted so far8 kg of CO2, made up
The widest count11 kg of CO2, made up
What the count includes: Plus 50 washes
Plus fifty washes and tumble-dries at home. In some studies this is the biggest part of a shirt's life.
Counted so far11 kg of CO2, made up
The widest count11 kg of CO2, made up
What the count includes: Plus growing the cotton
Plus growing the cotton: the fertiliser, the pumps, the land. The count has nearly quadrupled without the shirt changing.
Two labels say 4 kg and 11 kg for the same shirt. What is the likeliest reason?
The shirts must be different.
Not yet. Same shirt, same cotton, same washes. What differed is what the counter decided to include, which the label did not say.
One of them is lying.
Not yet. Neither needs to be. Four kilograms for the factory alone and eleven for a whole life of washing are both real counts with different edges.
They drew the edge of the count in different places.
Right. Lesson 10's edges again. Both can be honest counts of the same shirt. A label that does not say where its edge is cannot be compared with any other label.
Move the control.
In March 2024 a Dutch court examined 19 of KLM's green statements, such as flying responsibly and offsetting. How many did it find misleading?
Pick one. Nothing is scored.
15 of 19
of 19 statements found misleading
Most.Fifteen of the nineteen. The court found that the offset products overstated what offsetting achieves and that the slogans were too vague to be backed up. No fine: the campaign had already been withdrawn. Guesses land around half, because a court feels like a coin toss; a claim with no count behind it is not.
The packaging
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100 per cent sustainablesays who?
A shop's website says: our packaging is 100 per cent sustainable. What is that sentence?
A lie.
Not yet. Nobody has checked it either way, which is the point. Unchecked is not the same as false. That gap is why checkers exist.
A fact, because 100 per cent is a number.
Not yet. A number is a count only when the thing counted is named. A hundred per cent of what, against which tank, by whose edge? The sentence does not say.
A claim, only said: no count, no edge, no checker named. The kind the 2020 sweep flagged.
Right. Sustainable has not been given a meaning here, let alone a number. A sentence with a percentage in it is not a count until something has been counted.
Lesson complete
A claim is a sentence somebody said about themselves. A checked one has a count and a checker's name.