A poster for the product, seen in August last year, claimed the bars were ‘crammed with 100% natural ingredients’. One complainant believed the product contained ingredients that would not be understood as natural by consumers.
They challenged whether the claim ‘100% natural ingredients’ was misleading and if it could be substantiated.
United Biscuits said its use of the term ‘natural’ fit the criteria set by the Food Standards Agency (FSA) in 2008, which allowed ingredients to be classified as such if they were not chemically altered of produced using new technologies.
Degree of processing
The company provided a list of ingredients in the Go Ahead bars, bringing attention to how commonplace they were in consumers’ store cupboards. It did recognise that two ingredients, sunflower oil and fat-reduced cocoa powder, did undergo a degree of processing.
United Biscuits argued that both sunflower oil and cocoa powder were likely to be considered natural to the average consumer. It also noted that competitors used these ingredients in similar products, making similar claims.
The ASA considered that 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.
The watchdog referred to the FSA’s ‘Criteria for the use of the terms fresh, pure, natural etc. in food labelling’, which was based on research into consumer understanding of the term natural.
Only be produced by nature
Such ingredients could only be produced by nature and not the work of man or interfered with by man, with minimal processing to make them suitable for human consumption.
Under these guidelines, the production of sunflower oil and cocoa powder – which required the use of solvents and potassium carbonate solution respectively – was not natural.
The ASA deemed the ad in breach of the Code of Advertising Practice rule 3.1 for misleading advertising and 3.7 for a lack of substantiation.
The ad must not appear again in its current form. United Biscuits was told not to refer to ingredients as natural unless they were in line with consumer expectations of the term.