The issue with the Lipton Iced Tea product is whether the claim “100% RECYCLED” misleadingly implied that all of the Lipton bottle was made from 100% recycled plastic as the lid was excluded. The ASA considered consumers would understand the claim “100% RECYCLED*” alongside images of the bottle with the label and cap to mean that all components of the Lipton Ice Tea bottle (i.e. the bottle, cap and label) were made entirely from recycled materials even though the ad stated “Bottle made from recycled plastic, excludes cap and label”. THe disclaimer wording appeared in very small text in the left-hand bottom corner of the ad, and therefore it could be overlooked. 

Likewise, the Aqua Pura product declared  '100% recycled … bottle', '100% … recyclable bottle, 'eco-friendly cap and 'it’s nature friendly'. The ASA told Aqua Pura not to use the claim “100% recycled bottle” unless all the components of the bottle were recycled. Currently the Lid and label were not recycled. They also told them to ensure they did not overstate the environmental benefit of their brand and products, and did not claim that products made of plastic were “eco-friendly” or “nature friendly”. This is due to the fact that they had not seen evidence that demonstrated the Aqua Pura brand had a positive impact on the environment, nor had we seen evidence for the full life cycle of the products, and because parts of the products were made from a material that was inherently harmful to the environment, they considered the claim “nature friendly” overstated the environmental benefit of the brand and products and was therefore misleading.

Food Labelling Services comments: 

Although this is a UK ruling, it is felt that this should be used as a benchmark for all environmental claims. As predicted at the end of 2021, the ASA and CMA are increasing their focus on all environmental claims, and all claims should be honest and not mislead the consumer, as well as being able to be fully substantiated.

https://www.asa.org.uk/rulings/roxane-uk-ltd-g21-1120958-roxane-uk-ltd.html

https://www.asa.org.uk/rulings/pepsi-lipton-international-a21-1120048-pepsi-lipton-international.html

100% recycled bottle / 100% Recycled – this should mean all elements of the any packaging. Disclaimer statements will not be accepted. 

Recyclable bottle – ASA expect to see evidence that all components could be recycled.  

Eco-friendly  – is taken to be an absolute claim, meaning, it is not harmful to the environment in any way throughout the full life cycle of the product.  Absolute claims require a high level of substantiation.  This will include being littered and causing harm to wildlife, and ensuring that raw materials and processing do not have a negative impact on the environment.

Nature friendly – also an absolute claim and taken to mean the brand as well as advertised products are good for the environment.  Evidence required to demonstrate that the brand and the full life cycle of the products advertised had a positive impact.  

  In summary, these are key point to action:

• Do not state or imply that  product packaging is made from 100% recycled materials unless all components meet the criteria.
• Claims such as “friendlier” could be justified if the advertised product or service provided a total environmental benefit over that of the advertiser’s previous product or service or competitor products or services and the basis of the comparison was clear.
• Ensure you do not overstate the environmental benefit of the brand and products.