An energy industry gets called out for greenwashing, a food company gets zapped for misleading fat-content claims on its packaging, but a government agency investigated for hyping environmental problems?

That’s what’s been swirling in the U.K. since the Department of Energy and Climate Change (DECC) launched its nursery-rhyme-themed campaign last October, featuring, of all people, Jack and Jill and the Three Men in a Tub.
Reports by the Guardian say the $9.2 million campaign, by ad agency AMV BBDO, generated nearly 1,000 complaints to the U.K.’s Advertising Standards Authority (ASA), claiming everything from “scaremongering” to inaccurate climate change science to propaganda. In March, the ASA ruled that some of the language in the DECC’s print ads featuring ominous weather patterns “should have been phrased more tentatively,” but that the images of flood and drought were not exaggerated. That far from killed the “Act on C02” campaign — including this broadcast PSA, and the DECC is not rolling over.
This brings to mind two of EnviroMedia’s five Greenwashing Index criteria, set by University of Oregon advertising faculty, asking consumers to scrutinize words and images in ads before buying into green claims from big business. In the U.K., these same criteria are used by a media watchdog organization to scrutinize a government public service campaign for blowing environmental issues out of proportion.
Who is the ASA, and why doesn’t the United States have a similar organization? The ASA is “the U.K.’s independent regulator of advertising across all media, including TV, internet, sales promotions and direct marketing.” It’s funded by fees levied on advertisers by advertisers, meaning the U.K.’s ad industry is regulating itself. Here in the United States, advertising is regulated by the Federal Trade Commission (FTC). The same FTC that has spent the past two years deliberating whether to update (not enforce, just update) its 18-year-old “Green Guides,” which haven’t been updated for 12 years now. The same Green Guides whose update, said the American Advertising Federation (AAF), the American Association of Advertising Agencies, and the Association of National Advertisers, “would have a chilling effect on an advertiser’s ability to communicate important and valuable information to consumers.” C’mon now. EnviroMedia has been paying dues to our local AAF affiliate for more than a decade now. We can do better. We’re talking about an update of Green Guides no one even enforces.

Back to the Act on CO2 campaign. In my opinion, Jack and Jill, and you Three Men in a Tub, you might have a little “Chicken Little” going on. Extreme wet, dry, cold and hot are characteristics of climate change, which scientists say is caused by excessive CO2 emissions. Is the sky falling? No. Is the Earth’s overall temperature rising? Are glaciers melting? Yes, say the scientists. But if EnviroMedia were to be fortunate enough to help with a government-funded public service campaign to get as many citizens as possible to emit less C02, we probably wouldn’t start with ads featuring lovable children’s characters in danger of dying from thirst or drowning. The only thing obvious about climate change is that it’s controversial, so why fuel the fire by starting with a campaign featuring extreme consequences?
Just about anyone will agree wasting a limited natural resource is not a good thing – whether it’s water, coal, or oil. Our research has shown that the more people know about the natural source of their drinking water or the fuel that makes their lights go on, the more willing they are to be more efficient, or conserve. And we’ve seen measurable results in water conservation and renewable energy campaigns that directly connect the water tap or light switch to the consumption of limited natural resources. Couple that knowledge of natural resources with some simple – not extreme – tips for efficiency, and you can see better community buy-in and results – despite the political beliefs of your target audiences or related controversies.
Nursery-rhymes aside, bravo to the UK’s DECC for its overall Act on C02 program, and for reinforcing the IPCCs conclusions that climate change is connected to human activity. At least they’ve captured the attention of U.K. consumers and the world. Its campaign reminds me of this Environmental Defense Fund PSA I saw a couple of years ago. It follows a similar (scare) tactic, but seems more compelling and urgent than Jack and Jill — and is not coming from the government. (And yes, it was produced with the help of the Ad Council, a wonderful organization established long ago by the American advertising industry.)
I also applaud the ASA and U.K.’s advertising industry for its self-regulation, especially in the areas of environmental and health claims. Now, don’t ask me about these other ASA crack-downs on advertising condoms during the breakfast hour, or frightening children with scary ad spoofs of The Shining.





