The Advertising Regulatory Board (ARB) has dismissed a consumer complaint against Unilever South Africa over the claim “Long-lasting foam” on its Sunlight dishwashing liquid packaging, finding that the statement is adequately substantiated and not misleading.
Less soapy
In a decision issued on 19 February 2025, the ARB Directorate ruled in favour of the advertiser, concluding that the claim complies with the Code of Advertising Practice.
The complaint centred on the packaging of Sunlight dishwashing liquid with “Rhamno Power”. The consumer argued that the new formulation appeared less soapy or foamy than the previous version, requiring a greater quantity of product. She also said that the smell and consistency had changed, making the product feel inferior in quality.
In response, Unilever South Africa submitted documentary evidence to support the claim. The company provided a confidential substantiation report dated 3 September 2024, along with an independent expert assessment by Dr A Jardine, an associate professor and head of the Department of Chemistry at the University of Cape Town.
According to the advertiser, there is no universally accepted scientific method for measuring foam longevity. As such, the prior version of the product was used as an objective benchmark to maintain market relevance. Laboratory testing assessed flash foam, soil tolerance and foam regeneration using rotating cylinder methodology.
Dr Jardine’s report concluded that the new Sunlight AW25 formulation demonstrated statistically significant improvements in foam tolerance and foam regeneration compared to previously marketed products. They found that the evaluation of flash foam, residual foam and foam regeneration supported the “Long-lasting foam” claim. The report also stated that many thing affect how soapy water gets including the type of water in a consumers geographic region, eg. some areas have hard water.
The ARB Directorate first addressed the consumer’s concerns about changes in smell, feel and consistency. It noted that the packaging made no claims that the new product retained the same scent or texture as earlier versions. As a result, this aspect of the complaint was deemed irrelevant to the specific advertising claim under review.
Non-comparative
Turning to the foam claim, the Directorate considered whether Dr Jardine met the requirements of Clause 4.1.4, which mandates that documentary evidence must emanate from or be evaluated by an independent, credible expert in the relevant field. After reviewing the experts qualifications and experience — including a PhD from the University of Cape Town and previous acceptance as an expert by the ARB — the Directorate was satisfied that the criteria was met.
Importantly, the Directorate observed that the claim in question was “Long-lasting foam”, not “longer-lasting foam”. It noted that while the substantiation demonstrated superiority over previous formulations, the packaging claim itself was non-comparative. In its view, the expert evidence exceeded what was strictly required to support the claim.
“In the circumstances,” the ruling states, “the Directorate finds that the claim ‘Long-lasting foam’ is adequately substantiated … and is also not misleading.”
The matter was therefore dismissed.
