Background
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A website for Flooring by Nature, a carpet and flooring retailer, www.flooringbynature.co.uk, seen on 25 July 2024, featured a product listing for a “Wool Carpet” with text at the top that stated, “Their eco credentials mean they provide a fantastic, sustainable alternative to synthetic carpets […]. At Flooring by Nature, we stock a wide range of environmentally friendly flooring solutions, helping our customers make eco-friendly choices […]”. Further down the page, under the heading “Sustainable Wool Carpets to Suit your Home”, text stated, “Our sustainable wool carpets are woven from 100% natural wool, many ranges use undyed yarn so are chemical free, making them completely eco-friendly.
As sheep require regular shearing, wool is a sustainable resource, unlike the materials used for many other carpets which contain unnatural chemicals and plastics. Wool carpets also biodegrade at the end of their lives, meaning they are not adding to the ever-growing problem of excess waste, something which we take very seriously”.
Issue
The complainant, who understood some of the wool carpets used a plastic backing, challenged whether the following claims were misleading and could be substantiated:1. “sustainable alternative to synthetic carpets” and “eco-friendly”; and2. “Wool carpets also biodegrade at the end of their lives”.Response
Floor Design Ltd t/a Flooring by Nature said they had reviewed and amended their website in order to make the claims clearer and to signpost towards their Info Hub and FAQ pages. They said it was commonplace in the flooring industry for carpets to be referred to by their pile content, regardless of what type of backing they had. A carpet’s backing was a thin layer generally made of polypropylene, polyamide or a plant-based material such as jute or cotton. They said the most popular floors in the UK were 100% man-made fibre carpets and 100% vinyl hard flooring, both made from plastic. They aimed to offer more eco-friendly or sustainable alternatives, and their carpet piles were comprised of 100% wool or natural fibre.
1. Flooring by Nature said there was widespread acceptance that wool was a sustainable material. The addition of a plastic backing did not inherently make the carpet environmentally unfriendly or unsustainable. All but one of their carpet ranges with a plastic backing used a low-weight backing that required significantly less raw materials to produce than a standard plastic backing. As consumers had different priorities in terms of environmental impact, the raw materials for non-plastic backing were sourced from outside the UK and resultingly had higher manufacturing miles, whereas plastic backings were often manufactured within the UK and may have lower manufacturing miles. Carpets with less plastic and more renewable materials were more eco-friendly and more sustainable than carpets made entirely from plastic. They provided a journal article to support that point.
They said consumers had distinct interpretations of what the terms “eco-friendly” and “sustainable” meant, and they were confident their products would be considered eco-friendly by the vast majority of their customers. They said there were many metrics which could assess a product’s eco-friendliness or sustainability, and that listings for each of their individual products made clear the key attributes of that product.
2. Flooring by Nature said they made clear on individual listing pages which carpets were biodegradable, and that they only applied the term to plastic-free products. Those products were considered biodegradable as they were made from plant or animal fibres and if left to nature would biodegrade. They said they did not make claims in relation to how long it would take for their carpet to biodegrade, and nor did they realistically believe a customer would intend to allow their carpet to biodegrade at the end of its useful life. They said carpets were generally sent for incineration in a waste to energy facility, and due to waste treatment rules, carpets were rarely sent to landfill.
They said that for most consumers carpets were an infrequent and high value purchase, where they spent time considering their choices and understanding the information provided on each individual range as well as accessing the additional content in the FAQ and Info Hub sections of the website. Over 90% of their customers ordered free product samples prior to ordering, and the average timescale from sample order to purchase of a carpet was over 30 days, indicating it was a considered purchase and unlikely to be influenced by a small amount of content on their website.
Assessment
1. Upheld
The CAP Code stated that absolute claims must be supported by a high level of substantiation, but that claims such as “greener” could be justified if the advertised product or service provided a total environmental benefit over that of the advertiser’s previous product or service or competitor products or services and the basis of the comparison was clear. Additionally, marketers must base claims on the full life cycle of the advertised product, unless the ad stated otherwise, and must make clear the limits of the life cycle.
The ASA acknowledged the flooring industry referred to carpets by the material their pile was made from, regardless of what type of backing they had. Unless stated otherwise, we considered consumers would understand claims made about the carpet’s environmental impact as accounting for all of their components, including the backing.
We considered that consumers would interpret the claim “sustainable alternative to synthetic carpets” as meaning that all of Flooring by Nature’s woollen carpets had a lower environmental impact than that of a synthetic carpet when considering the full life cycle of each product. We reviewed the journal article provided, which outlined the estimated carbon dioxide equivalent (CO2e) emissions of wool and nylon carpets in the United States over their full life cycle. The article detailed the production of a 0.09 square metre of wool carpet and the same size of nylon carpet. The former had an estimated usage period of 25 years which resulted in 6.35 kg CO2e, and the latter had an estimated usage period of 11 years which resulted in 4.8 kg CO2e. Over a 25-year period, usage of a nylon carpet would result in more CO2e than a wool carpet, meaning in the longer-term usage of woollen carpets produced less CO2e. The article stated due to wool’s recyclability it was one of the most environmentally friendly floor covering products available. However, the article did not examine Flooring by Nature’s own woollen carpets and their full life cycle from production to disposal, and only compared pile made from wool or nylon and did not account for other synthetic materials such as polyester. For those reasons the evidence did not adequately substantiate the claim “sustainable alternative to synthetic carpets”.
We further considered the claim “eco-friendly” would be understood as meaning the carpets were not harmful to the environment at any point during their full life cycle. We therefore expected to see a high level of substantiation to support that claim. However, we had not seen evidence to support the claim, as it appeared, to that standard.
As we had not seen evidence that adequately substantiated the claims “sustainable alternative to synthetic carpets” and “eco-friendly” we therefore concluded they were likely to mislead.
On that point the ad, breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), and 11.1, 11.3, and 11.4 (Environmental claims).
2. Upheld
Flooring by Nature said that most carpets were incinerated at the end of their useful life. We considered consumers would understand the claim “Wool carpets also biodegrade at the end of their lives” as meaning all of the wool carpets shown, including the pile and the backing, were biodegradable, and stood a reasonable chance of biodegrading, at their likely-end-of-life destination.
We acknowledged that the wool used in the carpet’s pile could biodegrade, and that in making the claim Flooring by Nature had intended that it only refer to the woollen pile in the carpet, rather than the backing, which in some instances was made from the synthetic materials polypropylene or polyamide. However, for the carpets with a polypropylene or polyamide backing, and those with a cotton backing which could biodegrade, the ad did not make clear how to dispose of them, such as by including information about the environment they needed to be placed within to breakdown. We considered that information would be important to ensuring the product reached a suitable end-of-life destination in which it would successfully biodegrade. For that reason, we considered that information was material to consumers’ understanding of the claim and therefore should have been included in the ad.
The ad had suggested all of the carpets and their components, were biodegradable, and had not included sufficient information about how to dispose of them to successfully biodegrade. We therefore concluded it was likely to mislead.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), 11.1, and 11.2 (Environmental claims).
Action
The ad must not appear again in the form complained of. We told Floor Design Ltd t/a Flooring by Nature to ensure they held suitably robust substantiation for environmental claims, related to the full life cycle of a product where relevant. We also told them to ensure their ads made clear the actions consumers needed to take for the product to successfully biodegrade, and to make clear when they were only referring to part of a carpet.
