A TV ad for Dettol Spray Refills, seen on 21 May 2019, featured an empty plastic kitchen cleaner bottle floating in the ocean. The bottle was grabbed by a hand as the scene cut to a man cleaning the bottle in a kitchen sink. The voice-over stated, “Could we do something about the waste we produce?” The man then refilled the plastic bottle with surface cleaner liquid from a refill pouch and the voice-over continued, “Could refilling our spray bottles be a start? Try new Dettol Spray Refills with 70% less plastic and see what it triggers”.
Two complainants, who believed that the refill pouches were not widely recyclable, challenged whether the ad misleadingly implied the product was more environmentally beneficial than plastic surface cleaner bottles, which they understood were widely recycled.
RB UK Commercial Ltd t/a Dettol said that to support the claim, they included superimposed text in the ad which stated “Based on plastic weight per ML compared with 500ml Dettol Surface Cleanser”. They said the product, which weighed 17 g, enabled Dettol Surface Cleanser Spray Bottles, which weighed 56.32 g, to be refilled and therefore allowed consumers to save 70% plastic. Dettol said they understood that many local councils were not equipped to recycle the thin plastic used for refill pouches. However, they had partnered with TerraCycle to allow consumers to recycle the pouch with no additional cost. That required consumers to either search for a nearby public drop-off location to take the packaging to, create a public drop-off location by joining TerraCycle’s programme, or sign-up free of charge as a private collector and return packaging individually. Dettol said the ad highlighted the total environmental benefit of the use of refillable bottles and refill pouches as distinct to using bottles on one occasion only. Also, the development of a collection and recycling route for the pouches was an additional benefit that they had introduced which further encouraged consumers to adopt a refill and re-use approach. Dettol said they were willing to make changes to the ad to make sure the environmental benefits of the product were clearly explained.
Clearcast reiterated Dettol’s explanation of how the “70% less plastic” claim had been calculated. While Dettol had explained to them that the pouches might not have been recyclable, they considered that the ad did not suggest they were, and the main aim of the ad was to encourage consumers to continue to reuse their existing spray bottles by using pouches that used considerably less plastic.
The BCAP Code stated that environmental claims should be based on the full life cycle of the advertised product or service, unless the ad stated otherwise. It also stated that claims that were based on only part of an advertised product or service’s life cycle must not mislead consumers about the product or service’s total environmental impact. We understood that the “with 70% less plastic” claim related only to the reduction in the amount of plastic used to produce the refill pouches compared to the bottles, but the ad did not make that clear. We noted that in contrast to the bottles, the refill pouches were not widely recyclable. In the context of an ad promoting a new product that was said to reduce plastic waste we considered, therefore, that this was material information that consumers needed in order not to be misled as to the product’s total environmental impact. We welcomed Dettol’s willingness to make changes to the ad. However, because the ad omitted material information regarding the product’s total environmental impact, we concluded that it was likely to mislead.
The ad breached BCAP code rules 3.1, 3.2 (Misleading advertising), 9.5 and 9.8 (Environmental claims).
The ad must not appear again in its current form. We told RB UK Commercial Ltd t/a Dettol to ensure that their future advertising did not mislead consumers by omitting information about the total environmental impact of the refill pouches ‒ for example, by making clear that the claimed benefits of the product were in relation to the production of less plastic only and that there was only one mechanism through which the product could be recycled.