Proklean Technologies Private Limited - Profab Fabric Detergent

Recommendation: Upheld | Medium: Suo Motu - NAMS (TAMS)

The ASCI had approached the advertiser for its response in addressing the objections raised in the complaint. The advertiser was offered an option to seek an Informal Resolution (IR) of the complaint by modifying or withdrawing the claim objected to in the advertisement, or alternately to substantiate the claim with the required supporting data. The advertiser was also offered an opportunity for a telecon with the ASCI Secretariat, which they did not avail and submitted their response. The advertiser in their response stated that, “Proklean uses ingredients which originate from nature (mainly plants) to manufacture the cleaning products. These ingredients are non-toxic and biodegradable. This results in products which are non-toxic and readily biodegradable. The biodegradability of Proklean products have been evaluated in third party laboratories according to an OECD protocol. The test results are attached. After the products are used by the end consumer, when they are released into the environment through sewers, they readily biodegrade within a few days. As such Proklean products do not persist in the environment and are hence not harmful to the environment. Our Products are GreenPro certified”. As claim support data, the advertiser submitted the following documents – (1) Proklean Green Data, (2) GreenPro Certificate, (3) GreaseOut – Biodegradability report, (4) Biodegradability - ProFab Advance report, (5) Bio-degradability SupraKlean report. The advertiser’s response along with the claim support data was referred to an Independent technical expert of ASCI for an opinion in the matter. The expert’s opinion was then shared with the advertiser for making additional submissions. In response to the expert opinion, the advertiser submitted Proklean Green Data, and Proklean GreenPro Certificate. The additional submissions made by the advertiser were referred to the technical expert for final opinion. The Consumer Complaints Council (CCC) viewed the Website advertisement (https://prokleanhome.com/products/profab-eco-friendly-fabric-detergent-and-sanitiser1000-ml) considered the complaint, the advertiser’s response along with the claim support data, and the expert opinion presented at the meeting. The CCC observed that the advertiser has submitted biodegradability test reports for the product. These tests have been done by a third party, and are as per the established guidelines to test biodegradability. They have also provided GreenPro certificate for the product, and Proklean Green data - Summary of carbon footprint comparison with competition, water and energy consumption comparison with competition, and solar power generation data for the last six months. The CCC discussed that according to the advertiser, the raw materials used are biodegradable and non-toxic. There was no documented proof provided to back up this assertion. A list of all the chemicals, reagents, and solvents used in the process along with the information on their amounts, toxicity, and any applicable regulatory limits, were not provided. Further there was no data provided about the composition and fate of waste water generated. The advertiser has only provided proof that the product is biodegradable in itself. The CCC further discussed that the advertiser has asserted that the carbon footprint is 80% lower than that of chemical equivalents, which has not been supported by a systematic study. It shows that the manufacturing process has a non-zero (positive) carbon footprint (even if low). This contradicts the requirement of "not harmful to the environment" in order to be considered eco-friendly. The CCC then deliberated that the advertiser has also stated that the bottle packaging is made of HDPE, which is completely recyclable. The advertiser's response does not indicate whether the bottles are actually recycled. If not, there is a significant environmental impact. If the bottles are actually recycled, then the details about the recycling process and its impact were not provided by the advertiser. The CCC discussed that the advertiser claims that the production unit is entirely powered by solar energy. Given the intermittent nature of solar power generation, battery storage will be necessary. These batteries will have an impact on the environment (aside from the carbon footprint, such as water pollution and soil contamination). The CCC further discussed that The Confederation of Indian Industries (CII) provides the GreenPro rating and certificate as an eco-label. According to the GreenPro reference manual, a product is evaluated based on eight different criteria, including product design, raw material use, waste management, and life cycle approach. It has a defined method for awarding points based on these factors. As a result, GreenPro is a specific rating with its own standards, and a GreenPro rating does not imply that there is no environmental impact. It only confirms that the product meets a specific standard established by CII. As a result, it cannot be used to justify the "Eco-friendly" claim. The CCC then discussed that the Proklean Green data provides evidence that the products are environmentally friendlier and greener than those of the competitors. They do not provide enough evidence to claim an Ecofriendly label. The chemicals' and raw materials' toxicological information is not disclosed. The claim substantiation documents does not provide evidence that the entire content of the advertised product is eco-friendly, including, but not limited to the product, container/bottle, outer packaging material, etc. There was no supporting data to prove that their product (including the packaging) will be environmentally sustaining for the entire life of the product. Based on this assessment, the CCC concluded that the product packaging claim in the website advertisement, “Profab - Eco-friendly Fabric Detergent”, was inadequately substantiated. The claim is misleading by exaggeration and is likely to lead to widespread disappointment in the minds of consumers. The said claim contravened Chapter I, Clauses 1.1, 1.4, and 1.5 of the ASCI Code, and Clauses 1 and 3 of the ASCI Guidelines For Advertisements Making Environmental/Green Claims. This complaint was UPHELD.