ASA ruling on use of ‘100% natural ingredients’ claim

18th April 2018

A poster advertising campaign in August 2017 for Go Ahead Goodness bars made by United Biscuits claimed that the cereal bar was “crammed with 100% natural ingredients”.

The advert was challenged on the basis that the product contained ingredients that would not be understood to be ‘natural’ by consumers and so the claim of “100% natural ingredients” was misleading. The two key ingredients that were central to the issue were sunflower oil and fat reduced cocoa powder.

The Food Standards Agency published guidance in 2008 on the use of certain marketing terms including ‘natural’. The guidance noted that, providing the ingredients were not chemically altered or produced using new technologies, the ingredients could be classified as natural. It stated that products described as natural should be made using ingredients “produced by nature and not the work of man or interfered with by man”. Processing must be limited to that required as to render the product suitable for human consumption.

United Biscuits provided a list of ingredients found in their Go Ahead Goodness bars and stated that those ingredients were all made in a traditional manner and were typical of ingredients normally found in consumers’ food cupboards. They accepted that sunflower oil and cocoa powder did undergo a degree of processing however they were not new technologies and had existed for many years. In their view both cocoa powder and sunflower oil were readily found in people’s cupboards and were therefore likely to considered natural to the average consumer.

However the Advertising Standards Authority (ASA) did not agree and upheld the complaint. In the view of the ASA, consumers would understand the term natural in the context of the claim “100% natural ingredients” to mean the product was made using ingredients that were completely natural. They didn’t think that sunflower oil or fat reduced cocoa powder would be thought of as natural ingredients by consumers even though the processes used to obtain them were minimal. Therefore the advertisement was deemed to be misleading and ordered not to appear again.

WM Comment

This is a strict interpretation of the meaning of minimal processing within the context of ‘natural ingredients’ so care should be taken when making claims about natural products in the future.