Unilever will now have until the end of December 2026 to make the required changes across the affected Sunlight range.
The extension follows an earlier ARB ruling concerning the packaging of Sunlight Platinum. The Directorate found that the product’s front-of-pack claim that it contained “100% plant-based actives” contravened Clause 4.2.1 of Section II of the Code of Advertising Practice, which deals with misleading claims.
The complaint centred on the way the claim was presented to consumers. While the front of the packaging stated “100% plant-based actives”, the back of the packaging disclosed in smaller print that the product also contained “other non-plant-based additives”. The complainant argued that the two statements were contradictory: if non-plant-based ingredients were present, consumers could not reasonably understand the product to contain exclusively plant-based actives.
Unilever had argued that the claim referred specifically to rhamnolipids, which it said were a 100% plant-based active ingredient included in the product’s mix of active ingredients. The Directorate, however, found that this interpretation was not sufficiently clear. It determined that a reasonable consumer would most likely understand the claim to mean that the product’s actives were entirely plant-based, rather than that only one of its active ingredients was 100% plant-based.
The original ruling required Unilever to remove the “100% plant-based actives” claim from the front of the packaging within three months. The deadline was due to expire on 18 September 2026.
Unilever subsequently asked for an additional three months to implement the packaging changes, saying the updated products could then be available on the market by the end of December.
In its submission, the company explained that the claim does not appear only on Sunlight Platinum packaging, but across its wider Sunlight dishwashing liquid range. This means the change needs to be implemented across the portfolio and across several pack sizes, including 200ml, 400ml, 750ml and 1.5L formats.
Unilever told the Directorate that the revised artwork had already been finalised and supplied as evidence of the corrective steps it had taken. However, it said additional lead time was needed to produce and apply the new labels across the different packaging formats.
The company also warned that refusing the extension could result in significant revenue losses because Sunlight dishwashing liquid is a key product in its portfolio.
The complainant was given an opportunity to respond to the extension request but did not object.
In granting the extension, the Directorate noted that Unilever had indicated its intention to comply with the original ruling and had submitted its proposed updated packaging ahead of the existing deadline. It also considered the size and distribution of the Sunlight portfolio, the potential financial impact of the change and the absence of an objection from the complainant.
The ARB stressed, however, that granting the extension should not be interpreted as approval of the proposed new packaging. The Directorate said it cannot pre-clear advertising amendments and therefore would not comment on whether Unilever’s proposed changes adequately address the concerns raised in the original ruling.
Unilever therefore has until the end of December 2026 to amend the packaging on all products carrying the disputed claims.
