Advertisment
Website product listings:
Product 1: Firewood Bulk Bag:
A listing for a bulk bag of firewood included the following statements:
“Kiln-dried Birch logs are an outstanding energy-efficient and smokeless fuel source, with the capacity to produce an average heat output of up to 5.30 kWh/kg. Our kiln-dried wood maintains a moisture content ranging from 10% to 15%, significantly lower than the Government’s recommended limit of 25%. Additionally, it generates minimal ash content, leaving less than 1% residue behind.”
“Birch wood is prized for its high energy content and clean-burning characteristics, making it an ideal choice for heating, cooking, grilling, and creating cosy fires.”
“Our Rathwood Kiln-Dried wood is preferred for firewood as it burns more efficiently and cleanly compared to wood with higher moisture content. It ignites easily, produces less smoke, and generates more heat, making it an ideal choice for fire-starting and heating purposes.”
Product 2 – Firewood Dried Pallet
A listing for a pallet of wood included the above statements together with the following:
“Ireland’s No. 1 smokeless fuel, Eco Glow, is specifically manufactured for all Irish smokeless zones.”
Under the Product Features section it stated:
“Suitable for smokeless and non-smokeless zones”
Product 3 – Hardwood Firewood
A listing for a hardwood firewood pallet stated:
“Eco-friendly choice:
A carbon-neutral alternative to fossil fuels, exempt from carbon tax.”
Under the Product Features section it stated:
“Carbon-neutral”
Posts on the advertisers’ Instagram account featured various products.
Post 1:
The post featured an image of a bag of kiln-dried firewood. The post included the following statement:
“Birch wood is prized for its high energy content and clean-burning characteristics …”
Post 2:
The post featured an image of a bulk bag of oak firewood and included the following statements:
“Oak wood is prized for its high energy content and clean-burning characteristics:
It leaves minimal ash content
Less than 1% residue behind”
And
“RW fuels are made from FSC-certified woods from well-managed forests, further emphasising our commitment to environmental sustainability.”
Post 3:
The post featured an image of a bag of firewood and several bags of Eco-Stove coal. The post included the following statements under the ‘Product Features’ section:
“Sustainably sourced”
“Suitable for Smokeless & Non smokeless zones”
Complaint
The complainant objected to the claims that the products were ‘smokeless’, ‘clean burning’, ‘carbon neutral’ and ‘Eco-friendly” on the grounds that the claims were misleading and had made environmental claims about the properties of the products, implying that burning of the products was harmless and made no contribution to air pollution or climate change.
Response
The advertisers said that the advertising had been directed at a general consumer audience and that the wording of the advertisements aligned with commonly accepted descriptions of kiln-dried firewood and solid biomass fuels across the Irish and UK markets. They said that the terms were not intended to suggest absolute scientific claims, rather they were used to reflect well understood comparative qualities of kiln-dried wood compared with untreated firewood or fossil fuel alternatives.
They said that the term ‘smokeless’ was used in the context of wood fuels and was an industry-standard shorthand for low-smoke fuels such as kiln-dried logs, briquettes, and eco stoves. They referred to various other suppliers in the industry who marketed kiln-dried logs as ‘smokeless’ because they emitted significantly less visible smoke and particulates than wet or unseasoned wood.
They said that they had used the term in the comparative sense, i.e. that their products were suitable for use in smoke-controlled zones and emitted a lower level of smoke. They said that their interpretation was consistent with consumer expectations and was not presented as an absolute ‘zero emissions’ claim.
The advertisers said that the term ‘Clean Burning’ was widely normalised in the sector and was generally understood to mean that the wood, when kiln-dried to under 20% moisture content, burned more efficiently and with fewer particulates than unseasoned wood.
They provided a couple of examples of mainstream usage of the term, showing suppliers describing firewood logs as delivering ‘clean heat’ and stove manufacturers advertising their stoves as ‘clean burn technology’. They said that their use was consistent with these normalised standards and did not claim the total absence of pollutants but rather had communicated that kiln-dried logs were cleaner burning compared to alternatives.
In regard to the term ‘Carbon Neutral’/’Carbon Neutral alternative to fossil fuels’, they said biomass fuels, including kiln-dried logs were recognised by the EU Renewable Energy Directive (Red II) and Irish Government policy as a renewable, carbon neutral energy source when managed within sustainable forestry practices. They said that CO2 released on combustion was balanced by CO2 absorbed during growth. They said that the term was a fair and accurate comparative claim that reflected national and EU policy of treatment of biomass and aligned with consumer understanding that wood fuels were a renewable, tax-exempt alternative to coal, oil or gas.
They said that while lifecycle impacts such as kiln-drying were acknowledged, they did not alter the classification of biomass as carbon neutral under established regulatory and reporting frameworks. They said that the term was used in good faith, in line with accepted market and policy norms.
In regard to the use of the term ‘Eco friendly choice’, they said it was used in comparative sense, not in an absolute sense. They said that biomass was widely accepted as an eco-friendlier option compared with fossil fuels due to its renewable nature, exemption from carbon tax and reduced reliance on imported, high emissions fuels.
Finally, they said that many suppliers, manufacturers and even Government backed initiatives described wood fuels as ‘eco-friendly’ or ‘environmentally friendly’ in this comparative manner. They said that consumers reasonably understood such language to mean ‘more environmentally sustainable than coal, oil or gas, and not that the product was entirely impact-free.
Further Information:
The Executive reviewed the Air Pollution (Solid Fuels) Regulations 2022 which included a section on requirements for approved solid fuels which stated:
Requirements for approved solid fuel
5. (1) Solid fuel to be considered an approved solid fuel must conform with the requirements specified in the following paragraphs.
(2) Coal products and manufactured solid fuels must have a smoke emission rate of less than 10 grams per hour.
(3) Manufactured part biomass products must have a smoke emission rate of less than 5 grams per hour.
(4) Coal products and manufactured solid fuels, including manufactured part biomass products, must have sulphur content —
(a) less than 2% by weight on a dry ash-free basis, and
(b) subject to a market assessment, with effect from 1 September 2025, have sulphur content less than 1% by weight on a dry ash-free basis.
(5) Fuel products which are 100% biomass products, including wood products and wood logs, supplied in units of two cubic metres or less, must have a moisture content of —
(a) less than 25%, and
(b) with effect from 1 September 2025, less than 20%.
(6) Wood logs supplied in units of more than two cubic metres shall be accompanied by a notice containing the statement specified in Schedule 1.
1. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2018.328.01.0082.01.ENG&toc=OJ:L:2018:328:TOC
2. https://www.irishstatutebook.ie/eli/2022/si/529/
Conclusion
Complaint Upheld
The Complaints Council considered the detail of the complaint and the advertisers’ response.
The Council considered that the claims “smokeless”, “clean burning”, “carbon neutral” and “Eco-friendly” were absolute claims. They noted the Code requirement that environmental claims should not be used without qualification unless advertisers can provide substantiation that their product will cause no environmental damage and that absolute claims should be supported by a high level of substantiation (15.02). The Council noted that no evidence had been provided for any of the claims made in the advertisements. They considered that the use of such claims had the potential to mislead consumers and in the absence of any qualification for the claims, were in breach of Sections 4.1, 4.4, 4.9, 4.10 and 15.1 of the Code.
Action Required:
The advertising should not appear in its current form again.
The Council reminded advertisers that when highlighting the benefits of their products they should ensure that evidence is to hand, not to exaggerate these benefits and to consider using qualified claims.
