What the Latest ASA Rulings Mean for Travel Marketing: "Eco" Just Got Expensive

In each case, the environmental credentials behind the ads were real, with no false claims or fabricated certificates in sight. What tripped all three brands up was a single word: Eco.

Take the Thomas Cook case. Its ad promoted the 'Sandos Caracol Eco Resort' in Playa del Carmen, Mexico – a property with solar power, a water treatment system and an on-site nature reserve. But the ASA didn't dispute any of that. It ruled that 'Eco Resort' would be read by consumers as a description, not just a name, and because those genuinely positive initiatives were never explained within the ad itself, the claim was left unsupported. 

The ASA upheld complaints against Thomas Cook Tourism (UK) Company Ltd, We Love Holidays Ltd and Lotus Leisure Ltd (trading as DialAFlight), all for breaching CAP Code rules 3.1 and 3.3 on misleading advertising, alongside rule 11.1 on environmental claims specifically. loveholidays fell foul of it through two Google ads for the 'Green Garden Eco Resort' in Tenerife and the 'Marvida Family Eco Hotel' in Turkey, both names supplied by the properties themselves. DialAFlight's issue came from a Meta ad describing the Jumeirah Saadiyat Island resort in Abu Dhabi as 'eco-conscious', a line lifted straight from the hotel's own factsheet. And Thomas Cook's search ad wording had been generated automatically via Google's Performance Max, simply carried over from the resort's former name.

What's striking is that none of these cases began with a complaint. All three were flagged by the ASA's Active Ad Monitoring system, which uses AI to proactively search out ads that might be in breach. There were no fines attached this time round; the ASA required the ads to be amended or withdrawn. But it's worth remembering this sits within a far bigger structure, one where the CMA and the courts can fine up to 10% of global turnover for breaches of UK consumer law. The ASA ruling is really just the visible tip of it.

Here's what makes this ruling more useful than a straightforward telling-off.

The ASA didn't find that these properties had no environmental credentials. Sandos Caracol's solar power and nature reserve were real, as were Green Garden's plastic-free operations and Marvida's waste separation. The ASA recognised this in its own rulings. 

What fell short wasn't the sustainability work itself, but the explanation behind it. 'Eco' was being asked to do the job that a full sentence should have done, and without that context, the word ended up carrying more weight than it could hold.

So the takeaway is a friendlier one than the headlines might suggest. This isn't about needing a bigger claim, but a shorter one that's properly explained. The ASA has effectively ruled that a hotel's own trading name isn't a shield; if it reads like a claim, it needs to be backed up like one. Even the aggregator defence didn't stand up: loveholidays argued 'Eco' was simply part of a supplier-given name, not a claim of its own making, but the ASA found that consumers wouldn't draw that distinction; to them, the word still read as an environmental claim, whoever coined it. It's a useful reminder for any travel brand working through OTAs, marketplaces or affiliate feeds, where wording often travels further than anyone originally intended.

Good, we think, and it's been a long time coming. Saying 'eco' has always been free. Doing the work behind it isn't. That gap punished the hotels actually paying for the solar panels, the water treatment and the certification. Asking everyone to explain what they mean closes it.

Our one worry is fairness. A small independent hotel now has to meet the same standard as a big OTA with its own legal team. Smaller brands often have the better story, and they're the ones who'll find it hardest to prove. Ads are also being checked by AI now, so a problem can be flagged before a marketing team has even had a chance to look at its own live copy. That's especially true when the wording is written automatically or comes straight from a supplier feed.

None of this means the rulings are wrong. It means it's better to fix your wording now than wait to be told.

This isn't a one-off moment, either. Four cruise retailers, Barrhead Travel, Cruise1st, Cruise Circle and Cruise.co.uk, had sustainability claims upheld against them by the ASA back in September 2025, so the direction of travel has been building for a while. What's different this time is the method, since AI monitoring caught the issue before a single complaint landed, and the timing arrives just days ahead of the EU tightening its own rules further still.

From 27 September, the EU goes further than the ASA has. Directive (EU) 2024/825 adds generic terms like 'eco-friendly' and 'climate friendly' to a list of practices presumed unfair unless backed by recognised, evidenced performance, and private sustainability badges will need a proper certification scheme behind them from that point on. 'Carbon neutral' claims can no longer rest on offsetting alone either, which makes this the bar worth planning around for any UK travel brand running paid media into EU markets.

The short-term risk is what's sometimes called 'green hushing', where brands go quiet on real sustainability work simply because they're nervous, and that helps no one. The more useful, longer-term shift is towards proper third-party certification. It isn't a perfect fix, but it remains the fastest way to demonstrate credibility without writing an essay inside every ad.

The standard the ASA applied isn't complicated, and it's roughly what we already ask of any client claim:

• One qualified, specific claim that says exactly what it is
• One line of proof – what it's actually based on
• One easy next step – a click to the detail or evidence, not a wall of text in the ad itself

If a claim can't survive being asked "based on what, exactly?" it isn't ready for the ad yet.

Miles Lockwood, Director of Complaints and Investigations at the ASA, made a similar point publicly in July of this year: brands are free to use terms like "eco-friendly", but doing so invites a high evidential bar, and businesses are better served by precise, conditional claims – for example, framing a reduction in emissions relative to air travel – than by broad, unqualified language. (TTG, 2026) 

Ahead of publishing this blog, we spoke with Miles, who told us: “We recognise that travel brands are nervous about talking publicly on sustainability, fearful of being accused of greenwashing. But that silence just tips into 'greenhushing' –  and it's counterproductive when a brand has real, credible claims to make. Evidenced sustainability work can strengthen a proposition with consumers, not put it at risk. My advice to travel businesses: build claims on evidence you own. Say what you can prove, and be ready to prove what you say. ”

Sustainability messaging is where travel marketing's biggest opportunity and its biggest regulatory risk currently sit side by side. We help clients say the true, specific and interesting thing, and make sure it stands up once it's out in the world. Get in touch with us today.