Background
Summary of Council decision:
Three issues were investigated, all of which were Upheld.
Ad description
A website for baby product company Cheeky Panda, uk.cheekypanda.com, seen on 3 November 2025, included a listing for “Bamboo Nappies” which featured an image of the product packaging with text that stated, “SUSTAINABLE BAMBOO”. A section further down the page titled “Description & key features” stated, “Lining & absorbent core made from sustainable bamboo […] Breathable bamboo means they’re gentle on baby’s bum and kinder to the planet […] all while protecting the planet”. Further down the page a section titled “Seriously Good Stuff” included text that stated, “BAMBOO TO THE CORE. With a bamboo core and lining, our nappies use less plastic […] and keep the planet smiling”. A further section titled “Choose bamboo, for the love of trees!” stated, “Made from sustainable bamboo. Because trees belong in a forest, not circling down the loo or crumpled up in a wastebasket”.
A further listing for “Bamboo Baby Wipes” included an image of the product packaging with text that stated, “Biodegradable Baby Wipes” and “Biodegradable Fibres” Text alongside that stated, “Wipes that decompose faster than your kids grow up”. A section of the page titled “Description & key features” included text that stated “When you’re finished? Toss it. It’ll biodegrade, unlike that single-use wipe that could still be swirling in our oceans long after your little one is all grown up”. Underneath that a section titled “Composition & disposal” stated, “[…] 100% sustainable bamboo fibre […] Cheeky Panda wipes are biodegradable. Please dispose of used wipes in the bin, where they will naturally biodegrade”. Further down the page a section titled “Seriously Good Stuff” included the claim “BIODEGRADABLE FIBRES. Breaks down naturally, like bamboo should – no trace, no trouble”.
Issue
Procter and Gamble UK challenged whether the following claims were misleading:
- “Sustainable Bamboo” and “100% sustainable bamboo fibre”;
- “Biodegradable Baby Wipes” and “Biodegradable Fibres”; and
- “Kinder to the planet […] protecting the planet”.
Response
1. The Cheeky Panda Ltd (Cheeky Panda) said they were in the process of delisting their Bamboo Nappies product. They had intended the claim “sustainable bamboo” as highlighting the broader environmental characteristics of the raw bamboo used in their products. To that end, they had included text further down the webpage that stated, “Lining & absorbent core made from sustainable bamboo” and “less plastic” and referred to the composition of the packaging used. As part of their usage of bamboo as an alternative to conventional materials they had commissioned research into factors such as global warming potential, biodiversity and land and water use. They provided a life cycle analysis (LCA) report for their Bamboo Toilet roll product in support. They explained that although for a different product, the LCA made wider, cross-applicable observations about the environmental impact of bamboo fibre.
Cheeky Panda said they had used the claim “100% sustainable bamboo fibre” to describe the source material used in their wipes. The wipe sheet was made from 100% bamboo viscose, and they provided an independent ‘Fibre Analysis of Nonwovens’ test from May 2024 in support. The sheet also held a ‘Forestry Stewardship Council (FSC) 100%’ certification which they said confirmed the fibres originated from certified, well-managed bamboo sources with no uncontrolled or mixed content. They had consistently used bamboo as the primary material in their products and believed their marketing communications made clear they were referring to the characteristics of the material, rather than the environmental profile of the finished wipe. They provided a wipe fibre sheet analysis report and an FSC Chain of Custody Certificate and related documents in support.
Cheeky Panda said they had removed the word “sustainable” from the relevant claims and webpages.
2. Cheeky Panda provided a certification from the fibre manufacturer related to the material’s biodegradability. They had removed references to biodegradability from digital listings.
3. Cheeky Panda said they had intended the claim “Kinder to the planet […] protecting the planet” to highlight how the material used in their nappy linings and absorbent core differed from those used in conventional nappies and the benefit of that. They explained that the lining and core were made from bamboo and bamboo pulp, rather than the plastic and woold pulp common in standard disposable nappies. Their aim had been to raise the profile of bamboo’s effectiveness as a material compared to more traditional materials through the use of customer-friendly language, rather than to make broad claims about the environmental impact of the finished nappy. The context of the claim made it clear it referred to the bamboo specifically. They provided a UN report, a Department for Environment, Food and Rural Affairs (Defra) analysis of the LCAs of disposable and reusable nappies in the UK, and a journal article in support
Cheeky Panda said they had removed the claim from their website and other digital listings.
Assessment
The CAP Code required that the basis and meaning of environmental claims, and comparative environmental claims, must be clear, and that absolute environmental claims must be supported by a high level of substantiation.
1. Upheld
The listings included the claims "sustainable bamboo” and “100% sustainable bamboo fibre”. The listing for Bamboo Nappies made further claims about the product using less plastic, and we considered the text “Choose bamboo, for the love of trees” and “Because trees belong in a forest, not circling down the loo […]” implied the product used no tree-derived materials.
The ASA understood Cheeky Panda had intended the claims as relating to the bamboo component of their products, which they said had a lower environmental impact than widely-used alternatives, based on a comparison between the global warming potential, biodiversity, and land and water use of each. However, that information had not been included in the ad. We considered that, without further qualification, the claims were absolute claims about the bamboo used in the advertised products, and so we expected to see evidence relating to the full life cycle of the bamboo, as used in each product, from farming to disposal.
We assessed the evidence provided by Cheeky Panda. The LCA related to Cheeky Panda’s Bamboo Toilet Tissue product and covered the life cycle of that product, from farming to disposal. We acknowledged Cheeky Panda’s comments that the LCA made wider observations and comments about bamboo generally, including that bamboo forestry had a lower impact on biodiversity than pine. However, the disposal streams for toilet tissue, baby wipes and nappies were, when disposed of responsibly, different from one another. The LCA relied on the product being flushed after use, whereas that would not have been the case for responsibly-disposed of nappies and wipes. As a result, we considered the LCA was not cross-applicable. Additionally, the advertised nappies and wipes contained ingredients that were inextricable from the bamboo that would likely have given them a different environmental impact across their life cycle.
We understood FSC Chain of Custody certification was granted where the FSC had verified that forest-based materials had been produced according to standards relating to the sourcing of raw materials. Those standards took into account the life cycle of the material, from forest to sale of a finished product. However, while the certification showed Cheeky Panda’s products complied with those standards, it did not take into the account the use or disposal process of Cheeky Panda’s products. The wipe fibre sheet analysis report related only to Cheeky Panda’s facial wipes rather than the advertised wipes.
The basis of the claims had not been made clear, and we had not seen evidence based on the full life cycle of the relevant products to support the absolute claims “sustainable bamboo” and “100% sustainable bamboo”. We therefore concluded the claims were likely to mislead. We welcomed Cheeky Panda’s assurance they had removed the claims from their advertising.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 11.1, 11.3, and 11.4 (Environmental claims).
2. Upheld
The listing for Bamboo Baby Wipes made the claims “biodegradable baby wipes” and “biodegradable fibres”. Further text in the listing stated the wipes would decompose “faster than your kids grow up” if disposed of in a bin, leaving “no trace”. The ad made a comparison with single-use wipes, which it said “could still be swirling in our oceans long after your little one is all grown up”.
In that context, we considered consumers were likely to understand the claims as meaning the wipes in their entirety would fully biodegrade, more quickly than single-use plastic alternatives, and that no byproducts, or environmentally-harmful residue, would remain. They would additionally understand that biodegradation would occur in all conditions, states and bins in which the wipes might be responsibly disposed. The wipes comprised viscose fibre, to which water and other ingredients had been added, and we understood those ingredients were inextricable from one another. We therefore expected to see evidence relating to the wipes as a whole.
The Executive Summary showed the viscose used would biodegrade by around 80% over a timeframe of 122 days, at a temperature of 25 degrees Celsius. The report showed one of the byproducts of the material’s biodegradation was carbon dioxide. The evidence did not show the wipes as a whole would biodegrade in real world conditions in the way consumers would understand from the ad. The ad mentioned disposing of the wipes in a “bin”, but had not included information about anything that might interfere with the biodegradation process (such as contamination by organic matter), or the time the wipes would take to fully biodegrade. It had also claimed the wipes would leave “no trace”, when that was not the case.
We had not seen evidence the wipes as a whole would breakdown in the way consumers would have understood from the ad. The ad had also not included specific information relating to the method of disposal, length of time biodegradation would take, or any potential by-products. We therefore concluded the claims were likely to mislead. We welcomed Cheeky Panda’s assurance they had removed the claims from their advertising.
On that point, the ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), 11.1, and 11.2 (Environmental claims).
3. Upheld
We considered consumers would understand the claim “kinder to the planet […] protecting the planet”, in the context of the listing for Bamboo Nappies, to mean that because the nappies contained bamboo they were less environmentally damaging than nappies that used other materials, and that the use of bamboo was protecting the environment. We therefore expected to see evidence the nappies were less damaging to the environment than competitor products, and that by using the nappies they were making a better environmental choice.
We understood Cheeky Panda had intended the claim as referring to the fact their nappies used bamboo and bamboo pulp instead of plastic and wood pulp commonly used in nappies. However, that had not been set out as the basis of the comparative claim “kinder to the planet” in the ad. The UN and Defra reports both set out comparisons between disposable and reusable nappies, through examination of the LCAs of both. The UN report showed that the relative environmental performance of replacing plastic in single-use nappies with bio-based material was not clearcut. The Defra report, which compared LCAs from 2001 to 2002 for disposable nappies, home laundered cloth nappies, and commercially laundered nappies, found little difference in environmental impact between the three. The journal article was on the developmental biology of bamboo. We considered that evidence did not show Cheeky Panda were “protecting the planet”.
The ad had not explained the basis of the environmental claim, and comparative claim, made. Additionally, we had not seen adequate evidence to support the claim as it was likely to be understood. We therefore concluded it was likely to mislead. We welcomed Cheeky Panda’s assurance they had removed the claim from their advertising.
On that point, the ad breached CAP Code (Edition 12) rules 3.1, 3.3, (Misleading advertising), 11.1 and 11.3 (Environmental claims).
Action
The ad must not appear again in the form assessed. We told The Cheeky Panda Ltd to ensure the basis of environmental claims, and comparative claims, was clear, and that they held robust substantiation to support them.
