Ad description
An email from CLF Distribution, a health food wholesaler, seen on 10 December 2024.
The body of the email included the headline “These jams are crafted with high-quality, naturally sweet ingredients”. Below the headline, there was an image of four flavours of jam. Text within the image stated, “NO ADDED SUGAR? SWEET!”. Further text stated, “These jams are crafted with high-quality, naturally sweet ingredients that deliver all the fruity flavour and richness of traditional jams without the sugar spike”.
Issue
The complainant challenged whether the claim “naturally sweet ingredients” was misleading, because the products contained erythritol and steviol glycosides.
Response
CLF Distribution Ltd did not respond to the ASA’s enquiries.
Assessment
Upheld
The ASA was concerned by CLF Distribution Ltd’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay). We reminded them of their responsibility to respond promptly to our enquiries and told them to do so in future.
The ASA considered that traders would understand the term “naturally sweet ingredients” to mean the sweetening ingredients in the product were completely natural. We considered traders would understand that some processing may need to take place in order to make a naturally found ingredient fit for human consumption, but that such processing would be minimal. Ingredients which underwent more than minimal processing were unlikely to be understood as completely natural.
The jams promoted in the ad included the sweetener erythritol, a sugar alcohol. We understood that in commercial production, erythritol was manufactured through a corn fermentation process, rather than having been directly isolated or extracted from a plant. We further understood that the purification of erythritol typically involved an ion exchange. We considered those types of processing would not be understood by traders to be in line with their expectations of a sweetener described as a “naturally sweet ingredient”.
The jams also included steviol glycosides. We acknowledged that this sweetener was derived from a natural source, the stevia plant. However, we understood that to isolate steviol glycosides from the stevia plant, manufacturers used multiple chemical processes including extraction with solvents, filtration, ion exchange and crystallisation. We considered those types of processing were unlikely to be in line with traders’ expectations of a sweetener described as a “naturally sweet ingredient”.
For the above reasons, we concluded that the claim “naturally sweet ingredients” was not substantiated and therefore the ad was misleading.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation).
Action
The ad must not appear again in its current form. We told CLF Distribution Ltd not to claim or imply that their products containing erythritol or steviol glycosides contained only “naturally sweet ingredients”. We referred the matter to the CAP’s Compliance team.
