ASA Ruling on Intrepid Travel Group UK Ltd

In November 2022, a poster was seen on the London Underground for Intrepid Travel. The ad featured two women in front of the Giza Pyramids in Egypt, alongside the text “People & planet-friendly small group adventures since 1989”. A complaint was made to the Advertising Standards Authority (“ASA”). The complainant challenged whether the claim “people & planet-friendly small group adventures” misleadingly minimized the impact of Intrepid Travel’s holidays on the environment. By ruling of May 31, 2023, the ASA upheld that complaint. The CAP Code stated that the basis of environmental claims must be clear, and that unqualified claims could mislead if they omitted significant information. It also stated that claims must be based on the full life cycle of the advertised product, unless the ad stated otherwise, and required that marketing communications did not mislead consumers about a product’s total environmental impact. The Code further required that absolute claims were supported by a high level of substantiation. Intrepid Travel had commented that they did not offer flights as part of their travel packages, and that consumers would therefore understand that the claim was a narrow reference to their tour offering only. However, the claim was not qualified with that information. The presentation of the Giza Pyramids in Egypt within the ad, together with the claim “planet-friendly”, indicated that such tours were international and that it would be necessary to travel, in most cases by flying, to take part in their tours. The claim “people & planet-friendly small group adventures” was an absolute claim, which would be understood to mean that taking part in an Intrepid tour caused no environmental damage throughout its full life cycle. The ASA therefore expected to see evidence which demonstrated that taking part in an Intrepid Travel tour, including the necessary travel to and from the destination location, caused no environmental damage over its full life cycle. Whilst Intrepid Travel took part in a number of environmental schemes, these did not relate to the life cycle of a holiday with Intrepid Travel, and they had not been referred to in the ad. Also many of these initiatives were targeted to deliver results years into the future. Also, whilst Intrepid Travel had a carbon offsetting programme, resulting in it being certified as carbon neutral, Intrepid Travel did not calculate all greenhouses gases produced by their consumers travelling to and from their tour locations, nor did their offsetting programme take account of those emissions. Because air travel produced high levels of both CO2 and non-CO2 emissions, which made a substantial contribution to climate change, and those emissions were not accounted for by Intrepid Travel, the absolute claim “people & planet-friendly adventures” had not been adequately substantiated. The ad had misleadingly minimized the impact of Intrepid Travel’s holidays. The ASA ruled that the ad must not appear again in the form complained of. The ASA told Intrepid Travel to ensure that the basis of future environmental claims was made clear and did not give a misleading impression of the impact of their holidays, and that robust substantiation was held to support future claims. The ASA ruling explicitly found breaches of the following CAP Code rules:3.1 (Misleading Advertising) 11.1, 11.3 and 11.4 (Environmental Claims). Intrepid did measure some emissions from tour‑related transport within the tour itself (air, water, public, land. However, they did not include customer flights to and from the destination, which ASA considered essential to the full life cycle. ASA acknowledged Intrepid’s environmental programmes (e.g., SBTi membership, Seven‑Point Commitment Plan) but found they were irrelevant to substantiating the absolute claim. The ad was seen on 7 November 2022.