In a first for Singapore's greenwashing cases, the Advertising Standards Authority of Singapore (ASAS) has requested that a local company, Prism+, remove an advertisement from its Instagram page for breach of the Singapore Code of Advertising Standards' (SCAP) environmental claims guidelines. 

Prism+ is a Singapore company that sells smart air conditioners, monitors and 4K Smart TVs. They collaborated with a well-known local influencer, Xiaxue, to advertise their Prism+ zero smart air-conditioner. 

ASAS had received a complaint about Prism+'s advertising campaign for its air-conditioner. The advertising campaign had included a video featuring influencer Wendy Cheng (aka Xiaxue) on a mission to “save the earth”. In the video, Xiaxue puts on cold weather clothing and sets the temperature of her Prism+ air-conditioner to 23 deg C.

The video was captioned “Save Earth and electricity with 5 ticks energy saving” (Singapore’s classification system for the energy efficiency of electrical appliances is a system of ticks, with five ticks being the highest rating). 

The ASAS reviewed the advertisement and concluded that the language of the advertisement was in breach of the SCAP, in particular the claim that using Prism+ air-conditioners was the “best tip” to “save the earth” and the depiction of Xiaxue setting the temperature to 23 deg C as being able to achieve this aim.

The specific sections of the SCAP which had been breached by the advertisement were:

• the requirements that advertisements must not mislead by “inaccuracy, ambiguity, exaggeration or omission”; and 
• the requirement that advertisements must not misrepresent any matter likely to influence consumers’ attitudes to the product. 

Lastly, the ASAS reminded Prism+ that any claims made in advertisements must be capable of substantiation. 

While Prism+ has defended the advertisement as being “tongue-in-cheek” and satirical, it has also cooperated with the ASAS and removed the advertisement from its Instagram page. 

The SCAP does not have force of law. However, the ASAS can issue sanctions and/or require that the offending advertisement be removed. Separately, the Competition Commission of Singapore is also working on a detailed set of guidelines governing greenwashing claims in advertising. Read more here: Singapore: Greenwashing guidelines alert, Yue Lin Lee (dlapiper.com)

This landmark first decision in Singapore against an advertisement making greenwashing claims is a clear indicator of the ASAS and the public taking a more serious view of greenwashing claims. The actions of the ASAS are also aligned with the approach taken by regulators in other jurisdictions such as the UK. 

Companies intending to make environmental claims in their advertisements in Singapore must review their advertising copy carefully and ensure that: 

• all claims can be substantiated; 
• both words and actions in the advertisement are not at risk of being construed as misleading, exaggerated or ambiguous. 

In this instance, Xiaxue was not called out for her involvement in the advertising campaign. However, influencers collaborating with brands should also remain aware of their obligations under the SCAP and ensure that the content which they create for brands likewise does not end up being in breach of the SCAP.