ASA rules in favour of Shell again on green claims

For the second time in 2025 a greenwashing complaint has not been upheld by the Advertising Standards Authority (ASA) against an entity falling within the Shell corporate umbrella. Earlier this year the ASA sided with Shell UK Ltd in relation to a TV ad that the complainants alleged made misleading environmental claims (see our article here). Now, a ruling published in October 2025 has gone in Shell Energy UK’s favour, potentially indicating a more permissive approach by the ASA to green claims made by energy companies. See the full ruling here.

The Advert

This was a paid-for LinkedIn ad consisting of a video depicting imagery of the sun and solar energy, and on-screen text stating “What connects the Italian sun with bright engineering ideas? Our work with Baker Hughes to help meet their energy needs and decarbonise operations. Discover more at shell.com/progresstogether. Progress together”. 

The caption stated “Discover the progress we’re making together with Baker Hughes to help reduce their emissions and decarbonise their operations in Italy. Progress happens together".

The ASA’s Ruling

The complaint that the ad gave a misleading impression of the overall environmental impact of Shell Energy’s business activities was not upheld by the ASA. 

In their response to the complaint, Shell Energy claimed that, owing to various tags and interest-based targeting tools, the audience seeing the ad on LinkedIn would be “a sophisticated B2B audience with relevant knowledge and experience to understand the ad and its wider context”. The ASA disagreed on this point – they found that the audience would comprise both general consumers and a business audience. However, the ASA acknowledged that, since the ad content was focused on business solutions not available to general consumers, the audience would understand the ad as a B2B marketing communication. 

Significantly, the ASA emphasised that readers would be “unlikely to interpret the message as representative of Shell’s wider consumer-facing brand activity or as a comment on its own carbon transition plans”. Instead, readers would understand the ad to be a case study which showcased Shell Energy’s efforts to help a specific client, Baker Hughes, in decarbonising their operations. In this context, the ASA found that the ad was unlikely to mislead and the basis of the environmental claims was clear. 

Comment

With this ruling, the trend continues of the ASA taking a more lenient approach towards environmental claims made by companies operating within the oil and gas sector. There is, therefore, understandable speculation that these rulings have come in response to accusations of “green-hushing” and an overly prohibitive approach by the ASA to environmental claims in the past. However, while some businesses in carbon-intensive sectors may feel emboldened by this ruling, it is equally important to remain mindful of the CMA’s enhanced enforcement powers under the DMCC Act 2024 and the attractiveness of environmental claims by energy companies as a target for the CMA.

Two general learning points can be drawn from the Shell Energy ruling. First, the threshold for establishing that an ad has been targeted to a specific group (rather than consumers generally) is high, and tags and interest-based targeting on platforms like LinkedIn are unlikely to be sufficient. Second, it would appear the ASA is inclined to accept that where an ad is clearly put forward as a case study and the accompanying green claims are narrow and specifically tied to the work with a client, viewers will not consider the claims as representative of the business’s wider environmental activities. However, in view of the fact-specific nature of the decision and the absence of further explanation by the ASA around what qualifies as a case study, energy companies considering similar advertising should proceed with caution.