Unilever faces packaging compliance setback over ‘100% plant-based’ claim on Sunlight Platinum

SOUTH AFRICA – South Africa’s Advertising Regulatory Board (ARB) has ordered Unilever to change the “100% plant-based active” claim on the front of Sunlight Platinum dishwashing liquid packaging after ruling it misleading and a form of greenwashing. 

The complaint arose after a consumer noticed that while the front of the bottle prominently states “100% plant-based actives”, small print on the back reads “other non-plant-based actives are included”, creating what the complainant argued was a contradictory and confusing message for shoppers.

The complainant also pointed to strong hazard warnings on the back label, including advisories about skin irritation and serious eye damage, as unusual for a household dishwashing product, amplifying concerns about the “plant-based” messaging.

In its defence, Unilever explained that the claim is intended to highlight rhamnolipids (branded as RhamnoClean), a surfactant produced from sugar via biological fermentation and described as 100% plant-based, renewable and biodegradable. 

The company maintained that the back-label disclaimer is meant to clarify that, while rhamnolipids are plant-based, the formula also contains other non‑plant actives, and it submitted supporting evidence from Prof. Anwar Jardine, a chemistry expert at the University of Cape Town. 

Regarding the hazard statements, Unilever said these are required under the Globally Harmonised System (GHS) for chemical labelling and do not indicate that the product is unsafe when used as directed.

The ARB accepted that rhamnolipids themselves are 100% plant-based, but said the issue is how an ordinary consumer would read the front claim. 

The Directorate concluded that “100% plant-based active” is ambiguous and could reasonably be understood to mean the whole product is 100% plant-based, that the only active ingredient is plant-based, or that all ingredients are plant-based, with only one of those interpretations matching Unilever’s explanation. 

It further noted that the word “active” itself is unclear, as it could mean “active ingredient” or simply describe the product’s cleaning “action”, adding to confusion. 

The ARB ruled that relying on a back-label disclaimer to correct a misleading or confusing front-of-pack claim is not acceptable under the Code of Advertising Practice, and because plant-based claims carry significant weight with environmentally and health-conscious consumers, it viewed the headline claim as effectively a type of greenwashing.

Unilever has been instructed to amend or remove the “100% plant-based active” wording on the front of Sunlight Platinum packaging within three months, while the GHS hazard warnings on the back were deemed a regulatory requirement outside the ARB’s jurisdiction and remain unchanged.

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