In the Board meeting dated June 11, 2024 and numbered 346 published by the Advertisement Board ("Board"), advertisements containing environmental statements were put under the spotlight.
As it is known, pursuant to Article 17 of the Regulation on Commercial Advertising and Unfair Commercial Practices (“Regulation”), “Advertisements shall not be made in a manner that exploits consumers' sensitivity to the environment of their possible lack of knowledge in this area.” In fact, the Guideline on Advertisements Containing Environmental Statements (“Guideline”) which was adopted as a principle decision by the Board at its meeting dated December 12, 2022 and numbered 328, regulates in detail the correct use of environmental statements in advertisements. Following the Guideline, it is observed that the Board has examined the use of environmental statements more carefully, and within this scope, we have compiled below the sample decisions examined before the Board meeting numbered 346 and dated June 11, 2024.
1- Decision No. 2024/3966 on "Milka with very intense chocolate that thinks about nature as much as you do"
As a result of the examinations conducted by the Board, it was determined that the promotions made on the Instagram account included the statement "Milka with very intense chocolate that thinks about nature as much as you do." Subsequently, it was evaluated that consumers were misled about the product in question due to the fact that include the necessary information on what the statement was about, what it was used for and how it was used and whether it was for the whole or only a part of the product's life cycle. In this context, the Board decided to impose a penalty of suspension on the aforementioned advertisements.
2- Decision No. 2024/3967 on LC Waikiki "Nature Friendly"
As a result of the examinations conducted by the Board, it was determined that on the website a product can be labeled as "Eco-Friendly", "We used 30% less chemicals and saved 40% water with environmentally friendly production techniques in this product" and "Sustainability Detail: Environmentally Friendly" statements. The Board evaluated that the general terms such as “Eco-Friendly, Enviromentally Friendly, Environmentally Friendly Production Techniques” were not explained to consumers, and were used in a way to cause uncertainty before consumers regarding the environmental impacts of the production processes of the product and that the information of consumers was abused. In addition, it was determined that the statement "We used 30% less chemicals and saved 40% water with
environmentally friendly production techniques" is a "comparative environmental statement" and these statements should be proven by accredited institutions and organizations based on scientific studies, but were not proven, and it was decided to impose a penalty to suspend the aforementioned advertisements.
3- Decision No. 2024/3968 on Arçelik "Join the Climate Friendly Movement"
In the examinations made by the Board, it was determined that the promotions made on the Youtube account included the statements "Join the Climate Friendly Movement with (…) We continue to work for the good of the world with our climate-friendly products. Join the Climate Friendly Movement by using (…) let's change the future together..." and it was assessed that consumers’ information was abused by stating that these general terms were not explained to consumers and were used in a way that caused uncertainty for consumers regarding the environmental impacts of the production processes of the products. In addition, the Board emphasized that the statements “22 Tons of Water Savings per Year” and “32% Less Carbon Emission” were "comparative environmental statements" and that the necessary proof was not made. In conclusion, the Board decided to impose a suspension penalty on the aforementioned advertisements.
4- Decision No. 2024/3969 on Mavi "Recycled Sustainable Materials"
During the Board's review, it was determined that the website stated that "Mavi All Blue collection products use organic, recycled or Better Cotton licensed cotton, recycled polyester, TENCEL™ modal and lyocell, cottonized hemp and upcycled sustainable materials...". While these statements did not include information about the material content of the products in the collection in question, consumers may perceive that all of the products in the collection consist of the aforementioned materials, and that this issue exploits consumers’ environmental sensitivity and lack of information, and decided to impose a penalty to suspend the aforementioned advertisements.
As confirmed by these decisions, the Board does not allow the exploitation of consumers' sensitivity and sensitivities towards the environment by taking advantage of their lack of knowledge through misleading environmental statements.