Regarding terminology in UK, in December 2011 the Advertising Standards Authority (in an ASA decision which was upheld by its Independent Reviewer, Sir Hayden Phillips) controversially ruled that no manufactured product can be marketed as "zero-carbon", because carbon was inevitably emitted during its manufacture. This decision was made in relation to a solar panel system whose embodied carbon was repaid during 1.2 years of use and it appears to mean that no buildings or manufactured products can legitimately be described as zero carbon in its jurisdiction.