Advertisment
The campaign featured two radio advertisements as well as information on the advertisers’ own website regarding their product’s carbon neutral status.
The first radio advertisement featured the sound of a crackling fire and a voice over stating:
“What could be nicer in winter than a warm, cozy fire like this?
Well, how about a warm, cozy fire that’s good for the environment, good for the country and good for your pocket?
Willow Warm long-burning briquettes are 100% carbon neutral, grown and made here in Ireland.”
At the end of the advert, the voice over invites customers to visit the advertisers’ website:
“Willow Warm, the brighter, cleaner, greener way to a cozy home this winter. See Willow Warm.ie for stock lists.”
The second radio advertisement also featured the sound of a crackling fire and a voice over stating:
“You know me, I do like a home that’s warm and cozy during these cold winter months.
In fact, the warmer and cozier, the better. That’s why I insist on Willow Warm, long-burning briquettes.
They’re grown and made here in Ireland and they’re 100% carbon neutral. So Willow Warm briquettes are good for the environment, for the country, and your pocket.
Willow Warm, the brighter, cleaner, greener way to a cozy home. See WillowWarm.ie for stock lists.”
On the frequently asked questions (FAQs) webpage of the advertisers’ own website, text referring to the product’s carbon neutral status states:
“Any Carbon Dioxide (CO2) produced during not only the manufacturing process but also the burning of our finished product is completely offset by the growing stage of the willow crops themselves, as they take CO2 from the air through photosynthesis. In essence, the more willow that is grown, the more CO2 that is removed from the atmosphere, creating a cleaner environment.”
Complaint
Three complaints were received against the advertising.
Issue 1:
Two complainants objected to the claim in the radio advertisement that the product was “good for the environment” as they said the burning of any solid fuel could not be deemed to be “good for the environment”.
Issue 2:
One complainant said that the website claimed that the product was carbon neutral (even accounting for the manufacturing processes) because the growing process captured CO2. They considered this was misleading as any CO2 captured during the growing process was released into the atmosphere when it was burnt and that it was not being sequestered or even off set on a permanent basis. The complainant recognised that the product may be sustainable to a certain extent, however they questioned whether it was really carbon neutral unless there was an equivalent amount of CO2 being grown and carpeted by the advertisers that was not being burnt.
Response
The advertisers said that they took great care in creating their advertising to ensure that their audience was clearly informed as to the many environmental benefits of their product.
Issue 1:
The advertisers said that Ireland’s stated government policy regarding fossil fuel usage sought to reduce fossil fuel usage through the promotion of sustainable carbon neutral alternatives. They said that Willow Warm briquettes were a ‘carbon neutral’ replacement for products such as peat briquettes, imported brown coal lignite briquettes and coal. They said that the context for their statement “good for the environment” was intended to be viewed against the alternative use of fossil fuels such as turf/peat briquettes/lignite/coal/oil or gas, all of which were significant CO2 emitters and was intended as a comparative comment relating to the alternative fuel options, largely fossil fuels, which were not good for the environment.
They said that all materials used in the manufacture of Willow Warm Briquettes were sourced in Ireland from businesses operating under the strict regulation Forestry Stewardship Council (FSC) and all tree felling by the foresters was controlled through a legal felling licence. They said that Willow Warm used sawmill residues and pulpwood which contributed to completion of the carbon cycle of wood-based products and used zero additives, artificial ignition ingredients and did not use binders.
The advertisers referred to ‘Kyoto Forest’ and said that a significant portion of the harvest from the Kyoto Forest was destined for the energy market for heating and/or power generation. They referred to a report from 2009 titled “Climate Change and Irish Forestry” which set out that, as far as the climate was concerned, combustion of wood fuel was carbon neutral, if the harvested wood came from forests that were sustainably managed. They said that at the national accounting level, emissions from wood fuel combustion were not included in the energy emissions harvest. This meant, they said, that it was environmentally sound and economically prudent to use wood biomass for energy production, particularly in applications such as heating where there is high energy efficiency.
They said that Willow Warm utilised the part of a tree which was not usable for construction lumber and for this reason, it helped to maintain the entire life cycle of ‘wood based products’. To promote the economic development of the sawmill industry and forestry, they said that Ireland must have usage for all parts of the forestry material and their briquettes played an important part in helping to complete the cycle.
The advertisers stated that a willow crop had a lifespan of in excess of three decades and did not need to be re-ploughed, re-planted or re-seeded on an annual basis like many other crops so it was a sustainable use of land. They said that very little waste was generated during the manufacturing of wood-based products as almost all by-products were used, whether as a raw material or as an energy source. They said that using wood manufacturing by-products and end of life wood products as a source of energy was the final link in the wood cycle. Instead of the energy being wasted in landfill or forest brash allowed to rot on the forest floor, it provided a ‘carbon netural’ substitute for fossil fuels. As wood combustion only returned to the atmosphere the CO2 that had been taken from it by the growing of trees, wood combustion did not contribute to global warming or the greenhouse effect.
They said that wood contained little sulphur or nitrogen and as wood produced little ash, wood energy was clean. They said that their briquettes were an environmentally acceptable and that the SEAI recommended it as an alternative to fossil fuels for large parts of the population.
The advertisers said that with the cessation of peat harvesting and the recognition of both the economic and environmental pitfalls of importing fossil fuels, Willow Warm was leading the way in Ireland’s transition to renewable heat by introducing the indigenous, carbon-neutral product to the Irish market.
They said that to argue the difference between the words “better” and “good” was unnecessary and that they had rephrased their claim to state “better for the environment” which they considered was in line with the SEAI’s recommendation for energy users to ‘switch to using wood instead of fossil fuels like peat, coal or gas’.
Issue 2:
Regarding the complaint in relation to the information on the website pertaining to Willow Warm’s carbon neutral status, the advertisers stated that their briquettes fell within the defined international and national definitions of what defined wood as a ‘carbon neutral’ product. The said that the SEAI provided a contextual clarification of what constituted ‘carbon neutral’ stating that “Wood is CO2 neutral; the amount of CO2 given off by burning wood equals the amount taken in when the wood is growing”.
They reiterated that Willow Warm Briquettes were a 100% carbon neutral product made from a blend of completely renewable, Irish-grown willow and forest pulp wood. They said that it contained zero additives, artificial ignition ingredients or binders included and that in addition, they used parts of a forest tree which could otherwise be discarded or left to rot on the forest floor.
The advertisers said that when burnt, Willow Warm briquettes did not emit sulphur dioxide or exceed the carbon dioxide sequestered by the willow tree or forest tree while growing.
They said that Willow Warm was accredited by the Woodsure Ready to Burn and The Wood Fuel Quality Assurance schemes which supported clean air with carbon efficient fuel and reduced emissions.
They said that their FAQ page had covered two matters, firstly the burning of wood was carbon neutral and secondly, it had commented on the carbon footprint of their manufacturing process. They said that on reflection, and in the context of the ASA guidelines, they accepted that the FAQ could have been worded better as the text was open to interpretation, notwithstanding the fact that 77% of the production plant’s electrical consumption was provided by renewable power, they had removed the claim from the FAQ section of their website and from all marketing materials.
Finally, they provided documentation showing the level of sulphur dioxide of their briquettes at 0.01% and stated that coal had a typical sulphur content of 2% which was over two hundred times greater than the sulphur content of their product.
In a further submission, the advertisers said that their production plant had moved to being fully powered by 100% certified power.
Further Information:
The ASA Executive noted that Sustainable Energy Authority of Ireland (SEAI) stated “Wood is CO2 neutral; the amount of CO2 given off by burning wood equals the amount taken in when the wood is growing.”
https://www.eea.europa.eu/help/glossary/eea-glossary/kyoto-forest#:~:text=The%20Kyoto%20Protocol%20and%20the,Permalink%20to%20latest%20version%20dd6ff3af7caf4303b1b26e94a1a1872d
https://limerickandtipperarywoodlandowners.ie/wp-content/uploads/2024/04/Climate-change-and-Irish-Forestry.pdf
https://www.seai.ie/sites/default/files/publications/Post-Primary-Energy-and-Climate-Action-Use-Clean-Renewable-Energy.pdf
https://www.seai.ie/community-energy/schools/schools-documents/Post-Primary-Energy-and-Climate-Action-Use-Clean-Renewable-Energy.pdf
Conclusion
The Complaints Council considered the detail of the complaints and the advertisers’ response. They noted that the advertisements had been amended and the information that the production plant had moved to being powered by 100% green certified power.
Issue 1: Complaint Upheld
The Council noted that the claim “good for the environment” was an absolute claim. 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 the information provided, including evidence as to the level of sulphur dioxide. The Council also noted that the advertising had been amended to remove the claim ‘good for the environment’. The Council considered that the original claim was an absolute claim which had not been supported, therefore the Council considered that the reference to the product being “good for the environment” in the original advertising had the potential to mislead consumers and was in breach of the Code at sections 4.01, 4.04, 4.09, 4.10, 15.02.
Issue 2: Complaint Upheld
The Council noted the information provided from the SEAI in relation to wood being carbon neutral. However, they also noted that the ‘carbon neutral’ claim in the advertising had related not only to the burning of the finished product but also to the CO2 produced during the manufacturing process. They considered that evidence had not been provided to demonstrate that the manufacturing process was carbon neutral. They acknowledged that the claim had been removed from all marketing materials, however, as evidence had not been provided to substantiate the original claim, the Council considered that the unqualified reference to the product being carbon neutral in the advertising had the potential to mislead. The Complaints Council considered that the advertising breached the Code at sections 4.01, 4.04, 4.09, 4.10, 15.02.
Action Required:
As the advertising had been amended, no further action was required.
The Council reminded the 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.
