Sunlight dishwashing liquid, one of South Africa’s most recognisable household brands, has been ordered to amend a front-of-pack claim after the Advertising Regulatory Board (ARB) ruled that its “100% plant-based actives” wording was misleading.
The ruling concerns Unilever’s Sunlight Platinum dishwashing liquid and follows a consumer complaint over an apparent contradiction between the product’s front and back labels.
On the front of the bottle, the packaging prominently states “100% plant-based actives”. However, the back label, in noticeably smaller print, states that “other non-plant-based actives are included”.
The complainant argued that the wording created confusion and that the headline claim could not reasonably stand as presented.
In response, the ARB recorded that Unilever defended the claim on the basis that it referred specifically to rhamnolipids, a key surfactant ingredient used in the product. The company submitted a letter from the ingredient supplier confirming that rhamnolipids are derived from sugar, produced through biological fermentation, and are “100% natural”, with no petrochemical origin.
Unilever argued that this substantiated the claim that the ingredient itself is entirely plant-based.
The company further maintained that the statement was not presented in isolation, pointing to the disclaimer on the back label, which reads “#Rhamnolipids. Other non-plant-based actives are included”.
According to Unilever, this wording was intended to make it clear that, while the rhamnolipids are plant-based, the overall formulation includes additional non-plant-based active ingredients.
The ARB also noted that Unilever submitted documentary evidence, independently verified by Professor Anwar Jardine, associate professor, research scientist and head of the Department of Chemistry at the University of Cape Town.
His findings confirmed that rhamnolipids are 100% plant-based, renewable and biodegradable, while also being ultra-mild on skin and distinct from alternative surfactants.
However, the Directorate drew a clear distinction between whether the ingredient itself could be verified as plant-based and how the claim would likely be understood by consumers.
While it accepted that rhamnolipids are indeed 100% plant-based, it emphasised that this was not the issue in dispute. Instead, the matter turned on the overall impression created by the wording on the front of the product.
The Directorate found the claim “100% plant-based active” to be ambiguous, noting that consumers could interpret it to mean that the product itself is entirely plant-based, or that it contains only plant-based active ingredients. Neither interpretation reflects the full formulation.
This concern was reinforced by the prominence of the claim on the front of the bottle.
Positioned as a headline statement, the wording presents itself as a defining characteristic of the product, rather than a limited reference to one specific ingredient.
“The Directorate further notes that the word “active” may be taken to mean “active ingredient”, but it could also be an adjective (descriptive term) about the “action” of the product, making it unclear to the consumer what is actually being conveyed by the packaging. In addition, the “headline” nature of the claim leads the consumer to believe that this claim is pivotal to the nature of the product, which lends support to the idea that this is the only active ingredient,” stated the ARB.
While Unilever relied on the back-label disclaimer to clarify the position, the Directorate rejected this approach.
“Simply put, it is not permissible to make a statement that is confusing at best, and misleading at worst, on the front of a product, and then clarify on the back of the product that this is not the only active ingredient,” said the ARB.
The Directorate also highlighted the broader influence of plant-based claims, noting that such wording can carry particular weight among consumers seeking to reduce chemical exposure for health or environmental reasons.
This, it said, places a greater responsibility on advertisers to ensure that claims are precise and clear.
“Indeed, it is no doubt for this reason that the Advertiser has “headlined” this one active ingredient. This is, in effect, a type of greenwashing. This being the case, the Directorate finds that the claim made on the front of the product packaging is misleading and in breach of Clauses 2 and 4.2.1 of Section II,” stated the ARB.
Unilever has been instructed to amend the claim “100% plant-based active” on the front of the packaging to remove ambiguity and ensure compliance within three months, in line with the ARB’s Procedural Guide.
The ruling draws a clear distinction between what can be technically verified and what consumers are likely to understand from prominent packaging claims. It also reaffirms that product claims are assessed according to their overall impression, rather than isolated ingredient accuracy.
More broadly, the decision places pressure on brands to ensure that front-of-pack claims are clear and self-explanatory without relying on supplementary clarification elsewhere on the product.
It also signals closer scrutiny of “plant-based” positioning in consumer goods, particularly where such claims may carry environmental or health-related implications likely to influence purchasing decisions.
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One Response
To be honest I took a bottle of your dishwasher on holiday. I came back with eczema like sores between all my fingers. I will never use this particular product again.