Background
Summary of Council decision: Two issues were investigated, both of which were Upheld.
Ad description
Three Instagram posts on the account of Here We Flo, a period product company, seen on 12 January 2026:
a. The first post included a video of a person who said “[…] if it’s made with chlorine, bleach, or dyes, it’s a ‘no’ from me. Our [bleep added] deserve soft, and breathable, and plant-powered products […] Period care should be good for us, and good for the planet”.
b. The second post included a video of a person who held up a Flo branded pad and said “[…] they’re made with organic bamboo. It’s like sitting on a cloud [...]”.
c. The third post included an image with text that stated “YOUR FAVE PRODUCTS”, followed by a list of Here We Flo products. Under the “Eco-Applicator Tampons heading text stated “Made with organic cotton, grown without pesticides or herbicides, no irritating synthetic fibres. Under the “Ultra-Long Night Pads” heading text stated “Long double-winged absorbent pads that use bamboo viscose, made with organic bamboo so feels soft af on your vulva”.
Issue
&Sisters Ltd challenged whether the following claims were misleading:
- “plant-powered products” and “good for the planet” in ad (a); and
- “made with organic bamboo” in ad (b), “Made with organic cotton” and “bamboo viscose, made with organic bamboo” in ad (c).
Response
1. Here We Flo Ltd had intended the claim “plant-powered” to mean that a substantial part of the products were derived from plant-based materials, rather than that the products were wholly plant-based or had no environmental impact. They said the claim related to material composition only, not to full life cycle environmental benefit and that their pads and tampons contained a substantial proportion of plant-derived materials. They provided five studies that assessed the environmental impact of the manufacturing and supply of period care products, including those made with organic cotton and bamboo (organic bamboo was not considered) and conventional alternatives. A breakdown of the composition of their products was also provided.
They explained that their use of “plant-powered” was consistent with certification and regulatory frameworks and those frameworks outlined that plant-based claims did not necessarily require 100% plant composition.
They said the claim “good for the planet” was not a claim about a specific product nor in relation to their specific environmental impacts. Rather, they emphasised that, as the claim was prefaced by the word “should”, it outlined an opinion about the broad aspirational standard for the female hygiene and period care sector generally.
2. Here We Flo said the raw bamboo viscose and cotton fibres were certified as organic. The finished products were not presently certified as organic, and the claims in the ads related to the certified status of the raw fibres. Their tampons, both the absorbent core and the string, were organic cotton, and that their use of an oil derived hydrophobic coating on the string was consistent with standard practice for when manufacturing tampons. They said for their pads, the top was a blend of bamboo viscose made from organic bamboo and corn fibre. The side leak barrier, present in two of their seven types of pads, which were designed for heavy menstrual flows and incontinence, contained a minimal quantity of polyester. They explained that they had used the phrase "made with" in the ads was to ensure they did not imply the whole product was made of that particular material and just that a significant majority of it was.
The references to “organic” were to communicate that the raw materials used were not grown with chemical pesticides, herbicides, or fertilisers, and that they therefore had a reduced risk of those residues being on a pad that touches intimate skin, which was an important fact for their customers. They said a number of studies had highlighted the environmental advantages of bamboo as a biomass feedstock, and that they emphasised that its environmental impacts were highly dependent on processing methods and did not conclude that bamboo derived fibres were inherently unsustainable. They detailed that the bamboo viscose used in Here We Flo's products, as it was produced to a specific certified and audited standard, distinguished their fibre from historical open-loop viscose, meaning their fibre had a reduced environmental impact. However, they maintained that their usage and reference to organic bamboo alone did not mean their products were sustainable, and that the organic claim only related to the bamboo feedstock and was not making an environmental claim about the viscose process.
Assessment
1. Upheld
The CAP Code stated that the basis of environmental claims must be clear. It also required that absolute claims must be supported by a high level of substantiation, and they should be based on the full life cycle of the advertised product, unless the marketing communication stated otherwise, and made clear the limits of the life cycle.
Ad (a) stated “Our [bleep] deserve soft, and breathable, and plant-powered products […] Period care should be good for us, and good for the planet”.
We considered that in isolation the basis of "plant-powered" as an environmental claim was unclear. However, the ad's subsequent reference to "should be [...] good for the planet" added important context, which was likely to be viewed as related to "plant-powered" and from that consumers would understand the claims in conjunction with each other. We acknowledged Here We Flo had intended the claim "period care should be [...] good for the planet" as outlining a broad, aspirational opinion about the products and the female hygiene and period care sector. However, that basis had not been made clear. Consumers were likely to interpret the claim as meaning that Here We Flo's own products met the standards outlined, including that they "should be [...] good for the planet", and that they were able to do so because they were “plant-powered”. Within that context, "plant-powered" would be understood as meaning the different components of the products were entirely made from plants, would not contain materials derived from fossil fuels or other similarly environmentally harmful materials, and that "should be [...] good for the planet" would be interpreted as meaning the products would be beneficial for, or, at the least, not detrimental to the environment over the course of their full life cycle.
Due to how the ad presented “plant-powered” and “should be [...] good for the planet”, the claims were absolute and we expected to see a high level of evidence to support them.
We assessed the evidence provided by Here We Flo. The studies indicated tampons and pads made from organic cotton and bamboo (organic bamboo was not considered in the studies), could, potentially, in terms of the different forms of impact they could have on the environment, be at a lower level, including during the production stage, than when comparing that form of impact produced by conventional alternatives. However, the studies did not directly relate to Here We Flo’s products specifically. The studies demonstrated that the different forms of environmental impact that period care products produced, including during the production, were sensitive to various factors, and changes to those factors could affect the extent of their impact. We therefore considered the findings of the article could not be cross applied to the advertised products. Moreover though, the studies had not demonstrated that organic cotton or organic bamboo did not cause, across their full life cycle, no detrimental effect on the environment. We therefore considered that they were not adequate substantiation for the claims.
The composition breakdown of Here We Flo’s products showed that a significant proportion of the products were made from plants, including organic cotton and viscose from organically grown bamboo. However, it also outlined they were not made entirely from plants and each product respectively either contained plastic or an oil derived component. We acknowledged the proportion of non-plant-based components varied, and some were almost completely derived from plants. However, as the products were not entirely made from plants, and we had not seen evidence demonstrating the products across their full life cycle had no detrimental effect on the environment we considered the evidence had not adequately substantiated the claims.
As the basis of the claims “plant-powered” and “should be [...] good for the planet” had not been made clear, and we had not seen evidence to substantiate them as they were likely to be understood by consumers, we concluded the ads were likely to mislead.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation), 11.1, 11.2, 11.3, and 11.4 (Environmental claims).
2. Upheld
The CAP Code stated that before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. It also required that the basis of environmental claims must be clear.
Ad (b) stated “they’re made with organic bamboo. It’s like sitting on a cloud” in reference to Here We Flo’s pad and ad (c) featured the claims “Made with organic cotton” in reference to their Eco-Applicator Tampons, and “bamboo viscose, made with organic bamboo”, “no irritating synthetic fibres” and “so feels soft af on your vulva” in reference to their Ultra-Long Night Pads. Within the context of how they were presented within the ads, we considered consumers were likely to understand the claims “made with organic cotton” and “made with organic bamboo” to mean that the parts of the product that would be in contact with the skin and the absorbent parts of the product would be made from cotton or bamboo that was organic. Without qualification, we further considered consumers were likely to understand that the expected cotton or bamboo materials referred to in those claims was entirely organic.
The evidence provided showed that all Here We Flo products contained organic certified cotton and bamboo fibres, including that the cotton used in the tampons was entirely organic. However, it also demonstrated that the organic fibres in their pads were blended with non-organic material, including but not limited to, Forest Stewardship Council (FSC)-certified wood pulp. We also understood that not all of the parts of their products that would be in contact with the skin were entirely made from organic material. For example, the topsheet of their pads contained corn derived polylactic acid (PLA), a biopolymer that was not organic and the string of their tampons had an oil derived hydrophobic coating which, while not invalidating the organic status of the cotton used, would nevertheless be in contact with the skin. Additionally, the absorbent core materials used across their range of pads, was not made from organic material, and the side leak barrier, separate from the topsheet and absorbent core, present in two of their seven types of pads, which were designed for heavy menstrual flows and incontinence, was made from polyester fabric.
As the expected parts of the products either blended organic and non-organic materials together or did not contain any organic material, the claims in the ads had not been adequately substantiated in terms of how consumers would understand them and their basis had not been made clear. We therefore concluded the ads were likely to mislead.
On that point, ads (b) and (c) breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), 3.7 (Substantiation), and 11.1 (Environmental claims).
Action
The ads must not appear again in the form complained of. We told Here We Flo Ltd to ensure the basis of environmental claims, such as “plant-powered” or “good for the planet” were made clear, that they held a high level of evidence to support any absolute environmental claims made in their ads, and that they made clear the extent of any organic certification.
