NAD Finds Certain Environmental Benefit Claims for Quilted Northern Ultra Soft & Strong Bathroom Tissue Supported; Recommends Modification of Others
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New York, NY – September 28, 2021 – The National Advertising Division (NAD) of BBB National Programs determined that Georgia-Pacific Consumer Products LP provided a reasonable basis for the environmental benefit claims referenced below for its Quilted Northern Ultra Soft & Strong Bathroom Tissue, including tree-planting claims, energy-efficient-manufacturing claims, real-life energy and water savings examples, and sustainability claims, and that all such claims were substantiated. NAD recommended, however, that certain claims be modified to more clearly disclose the basis for the claims and to avoid communicating unsupported messages.
The claims, which appeared on the advertiser’s Quilted Northern website and product packaging, were challenged by NAD as part of its independent routine monitoring of truth and transparency in U.S. national advertising.
NAD determined that the advertiser provided a reasonable basis for the claims:
- “3 trees planted for every tree used.”
- “Our plan is to plant 2 million new trees by the end of 2021.”
As support for its claim “3 trees planted for every tree used,” Georgia-Pacific demonstrated that it accurately tracks the number of trees consumed throughout its manufacturing process and that it can ensure that three trees are regrown for each tree used. Further, with regard to the aspirational claim that “our plan is to plant 2 million new trees by the end of 2021,” NAD concluded that the advertiser adequately demonstrated that it is committed to achieving its goal to “plant 2 million trees” and that it has implemented a plan to do so.
NAD determined that the advertiser provided a reasonable basis for the claims:
- “[o]ver 90% of bath tissue’s environmental impact occurs in the manufacturing process.”
- “Our proprietary, efficient manufacturing technology squeezes out more water from the paper before drying. This saves 30% more water and uses 30% less energy.”
NAD found, however, that while these two highly technical claims are literally true, it is not necessarily clear that the environmental benefit being touted relates to one specific step in the manufacturing process. Therefore, NAD recommended that Georgia-Pacific modify these claims to more clearly disclose that the 30% savings is limited to a portion of the manufacturing process and not the total environmental impact of its product.
Further, NAD determined that Georgia-Pacific’s “Energy Efficient Manufacturing” claim, which communicates the message that its manufacturing process uses less energy to perform the same function as competing processes, was substantiated.
Real-Life Energy and Water Savings Examples
NAD determined that the advertiser provided a reasonable basis for its real-life energy and water savings examples:
- “If everyone in the U.S. who bought Premium 2-ply toilet paper switched to Quilted Northern Ultra Soft & Strong for 1 year, we would save enough water to:
- Take over 7.5 million showers.
- Provide almost half of the United States’ population with a day’s worth of drinking water.
- Flush a toilet 25 million times.”
- “If just one household switched to Quilted Northern Ultra Soft & Strong for a year, it would save enough energy to:
- Watch 21 college football games.
- Microwave 104 bags of popcorn.
- Charge a smart phone battery every day for 5 years.”
NAD was satisfied that robust disclosures explaining the basis of the calculations made the claims understandable to consumers. Further, NAD was sufficiently persuaded that reasonable consumers would understand that the examples were illustrative and based on hypothetical usages and would accurately get a sense of the scale of energy and water savings afforded consumers that choose Quilted Northern Ultra Soft & Strong.
However, NAD found that the advertising does not make clear the savings resulting from switching to Quilted Northern would only accomplish each example individually, as opposed to all the examples together. Therefore, NAD recommended that Georgia-Pacific modify the presentation of the claims to avoid the unsupported message that switching to Quilted Northern Ultra Soft & Strong would save enough water or energy to accomplish all the savings in aggregate.
NAD determined that the claim “Premium comfort made sustainably,” as it appears on both the back of product packaging and on the advertiser’s Quilted Northern website, conveys a supported message about specific environmental benefits provided by purchasing the product. However, NAD recommended that the advertiser discontinue or modify the front of package claim by clearly qualifying it so that consumers understand that “sustainably” is limited to the specific highlighted environmental benefits (i.e., tree planting and energy efficiency).
Regarding the claim “premium design with the environment in mind” on the advertiser’s Quilted Northern homepage, NAD determined that usage of a “learn more” hyperlink to a page containing information on the specific environmental benefits of the product appropriately qualified this general benefit claim. However, NAD recommended that the advertiser modify the label of its disclosure hyperlink to more clearly indicate the nature of the information to be found by clicking on it.
As for the instance of this claim that appears in a banner at the top of the Quilted Northern Ultra Soft & Strong sub-brand page, NAD was satisfied that the context in which the claim was presented – in close proximity to other claims about the environmental benefits of the product – adequately qualified the claim.
Finally, during the pendency of the proceeding, the advertiser informed NAD that it would voluntarily discontinue the claim “You don’t have to choose between comfort and sustainability. You can have both.” Therefore, NAD did not review this claim on the merits.
In its advertiser statement, Georgia-Pacific stated that it “will comply with NAD's decision.” Further, the advertiser noted that it “disagrees with NAD’s recommendation that a few claims be modified to avoid any unsupported message but appreciates NAD’s careful consideration of the issues presented and will take into account NAD’s recommendations and adjust such claims accordingly.”
All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive.
About BBB National Programs: BBB National Programs is where businesses turn to enhance consumer trust and consumers are heard. The non-profit organization creates a fairer playing field for businesses and a better experience for consumers through the development and delivery of effective third-party accountability and dispute resolution programs. Embracing its role as an independent organization since the restructuring of the Council of Better Business Bureaus in June 2019, BBB National Programs today oversees more than a dozen leading national industry self-regulation programs, and continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-directed marketing, and privacy. To learn more, visit bbbprograms.org.
About the National Advertising Division: The National Advertising Division (NAD) of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. NAD reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.
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