ASA Adjudication on Rockwool Insulation Ltd
Rockwool Insulation Ltd
26-28 Hammersmith Grove
14 October 2009
Number of complaints:
Two trade press ads for insulation material.
a. The first ad stated "Insulation for life. 100% recyclable, less waste, less landfill. Made from a totally natural material taken from renewable sources, Rockwool is safe to work with and to live with. Waste is recyclable and stone wool does not degrade over time. Added to this, Rockwool's genuinely non-combustible nature, thermal insulation qualities that conserve energy, and excellent acoustic performance, and you will understand why, in every sense, this is insulation for life … NON-COMBUSTIBLE, 100% RECYCLABLE, 100% RIGHT."
b. The second ad showed three children with the figures 1, 2 and 3 over their heads. The text stated "You can count on it … Rockwool's insulation is non-combustible, 100% recyclable and 100% right for school specification. Rockwool is an insulation material that does not burn, as well as offering excellent thermal and acoustic insulation. It is also totally natural, taken from renewable sources, 100% recyclable, safe to work with and to live with. The benefits of Rockwool may not be immediately visible but they are very real … NON-COMBUSTIBLE, 100% RECYCLABLE, 100% RIGHT."
BRUFMA, the European Phenolic Foam Association and Kingspan Insulation Ltd challenged whether the claims:
1. "100% recyclable" was misleading and could be substantiated; and
2. "Made from a totally natural material taken from renewable sources" was misleading and could be substantiated.
CAP Code (Edition 11)
1. & 2. Rockwool Ltd said they provided a service whereby they recycled the product returned by customers. They said they not only encouraged the return of Rockwool off-cuts, but also any of the product that had been reclaimed during refurbishment or demolition work. Rockwool pointed out that the Environment Agency authorised them to recycle their insulation products recovering the 'recyclate' and then incorporating it as part of the process of manufacturing new product. They said they had invested a large sum of money in opening a new recycling facility capable of meeting growing customer demand for recycling for the foreseeable future. They maintained that there were no Rockwool mineral wool insulation products that were not suitable to be recycled in that way.
Rockwool acknowledged that contamination of the product was caused by material such as brick or wire being attached to the used Rockwool product when it was returned to Rockwool for recycling. They accepted that they could not recycle items such as bricks and wire, but maintained that most of such materials would normally be removed at the demolition site. Rockwool pointed out that many sites had to have a recycling facility where waste could be sorted. They added that, even if the used product had been in contact with water or non-hazardous chemicals, it could still be recycled. They also maintained that simple screening to remove obvious foreign objects and to ensure that no hazardous chemical contamination had occurred was all that was necessary to process the used material for recycling.
Rockwool accepted that they could not account for what those responsible for waste management in the construction industry at large did with their old Rockwool products. However, they maintained that, if asked, they could recycle their customers' waste materials. They provided figures asserting that they had, from 2008 onwards, begun to recycle significant quantities of used Rockwool product at their new facility. They also pointed out that they had developed a collection service intended to make it more practical for their customers to recycle the used product.
Rockwool sent a copy of a report from the Nordic Center for Earth Evolution and Natural History Museum of Denmark, University of Copenhagen entitled "The human impact on natural rock reserves by using basalt, anorthosite and carbonates as raw materials in insulation products". They maintained that it demonstrated that the materials used to make Rockwool insulation were natural and taken from what could be considered renewable sources. They acknowledged that a very small proportion of the product, some 3%, comprised of oil based products and binder, which were burnt off in the recycling process. They pointed out, however, that 97% of the materials used in the entire Rockwool production process, not just those that resulted in the finished product, were natural materials or recycled by-product materials.
The ASA noted the complainants' assertion that, because the Rockwool product was often contaminated with other building materials, it was unlikely in practice that the product would be recycled in most cases. We noted, however, Rockwool's argument that the product was recyclable as it could be decontaminated and returned to their recycling facility via their collection service. We also noted the figures they sent showed a significant increase in the quantities of used product being recycled at their plant.
Although we acknowledged that Rockwool had demonstrated that their product could reasonably be regarded as 'recyclable', we considered that the claim went further and, because it stated "100% ...", readers were likely to infer that the entirety of the Rockwool product was capable of being recycled. We understood, however, that a small proportion of oil based products and binder could not be recycled into the new product and were burnt off during the recycling process. Consequently, we concluded that such an absolute claim was likely to mislead.
On this point, the ad breached CAP Code clauses 3.1 (Substantiation), 7.1 (Truthfulness), 49.1 and 49.2 (Environmental Claims).
2. Not upheld
We noted the ads stated that Rockwool was "Made from a totally natural material taken from renewable sources" and noted the study sent by Rockwool had concluded that their use of mineral resources was sustainable and that they could be considered renewable in a geological sense. We also noted they acknowledged that the product also included a small proportion of oil based products and binder, which were not from renewable sources. However, we considered that readers were likely to understand that the claim was a reference to the primary material used and would understand that other materials were used in the product and production process. We therefore concluded that the claim was unlikely to mislead.
On this point, we investigated the ad under CAP Code clauses 3.1 (Substantiation), 7.1 (Truthfulness), 49.1 and 49.2 (Environmental Claims) but did not find it in breach.
The ads must not appear again in their current form.
On point 1, we told Rockwool not to use such an absolute claim again.
Adjudication of the ASA Council (Non-broadcast)