This article is a method rather than an argument. Anyone can apply it to any claim they encounter, and it produces a defensible answer in about five minutes.
The test
Four questions, in order.
- What would an ordinary reader take this to mean? Not the narrowest technically defensible reading, but the impression created by the claim in context, including imagery, placement and prominence.
- Is there a definition or standard for that meaning? If the words correspond to a defined property with a test method, substantiation is possible. If not, it is not.
- What evidence would support it, and is that evidence held? The advertiser must hold documentary evidence at the time the claim is made, not assemble it afterwards.
- Does any qualification change the meaning, and is it prominent enough? A qualification that materially alters a headline claim cannot sit in small print or a footnote.
Those questions come from the general principles applied to advertising claims and from the Green Claims Code, and they are the framework the Advertising Standards Authority applies in the rulings it publishes.
Worked through, on the claims this category actually uses
Reef safe
Ordinary meaning: this product does not harm coral reefs. Definition or standard: none exists. Evidence that could support it: an assessment against criteria that do not exist. Result: no substantiation route. This is why the status recorded in reef safe and the coral evidence is unsupported rather than contradicted; there is nothing to check.
Free from oxybenzone and octinoxate
Ordinary meaning: these two named substances are not in the product. Definition: the substances have INCI names and are identifiable. Evidence: the formula. Result: substantiable and checkable. Note that under the advertising rules, free from claims should not imply that the named substance presents a hazard where that has not been established, which is where such claims most often run into difficulty.
Biodegradable
Ordinary meaning: this breaks down harmlessly in the environment. Definition: standard test methods exist, each with stated conditions. Evidence: a test result under a named method, for a stated scope. Result: substantiable if qualified, problematic as an absolute claim, and inapplicable to the inorganic filters. Set out in biodegradable and marine claims.
Ocean friendly
Ordinary meaning: this is better for the sea than alternatives. Definition: none. Comparison: unstated comparator, so the comparison cannot be fair or meaningful. Result: no substantiation route, and an additional failure on the comparison principle.
Made with natural ingredients
Ordinary meaning: most or all of what is in it is natural. Definition: no legal definition, though calculation methods exist. Evidence: a natural origin index under a stated method. Result: substantiable if the method and scope are stated, and misleading by omission if a small proportion of natural content is presented as characterising the product.
Our sunscreen is ocean friendly
- What would have to be true
- An ordinary reader's understanding of ocean friendly, which is that the product does not harm marine life or does less harm than alternatives.
- Criteria defining that property, a method of assessing a product against them, and evidence held at the time the claim was made.
- For any comparative element, a stated comparator and a fair basis of comparison.
- What is established
- Environmental claims in UK advertising are subject to published requirements, including that claims be substantiated and that comparisons be fair and meaningful.
- Some narrow environmental properties, such as ready biodegradability of a named ingredient under a stated method, can be substantiated.
- What is not established
- That ocean friendly has any criteria, method or verifier.
- That a comparator is stated or implied in a way that could be assessed.
- That any product has been assessed against marine outcomes in a way that would support the claim.
What a defensible claim looks like
Narrow, specified and boring. A statement that a named ingredient meets a defined standard for ready biodegradability under a named test method. A statement that a formula contains no substance from a named legislative list. A statement of a natural origin index with the calculation method and whether water is included. A statement that packaging is made from a stated proportion of recycled material.
Each of those tells a reader something and each can be checked. None of them is exciting, which is precisely why they are rare.
Evidence has to exist when the claim is made
One procedural point catches more advertisers than any question of science. The evidence for a claim has to be held at the time the claim is made, not assembled after it is challenged. A company that publishes a marine claim and then commissions work to support it has already been in the wrong for the period in between, however the work turns out.
This matters in a fast moving category, because claims frequently migrate. A phrase used on one product, where it was narrowly true and properly qualified, gets lifted onto a second product where the qualification does not apply, then onto a range page, then into a social post where the qualification has no room to travel. Each step is made by somebody who saw the claim already in use and reasonably assumed it had been cleared. Nobody checks, because the claim looks established.
The remedy is unglamorous and it works: keep a substantiation file keyed to the exact wording, and treat any change to the wording as a new claim needing its own check. That is what a regulator will ask for, and it is also the discipline that stops a category drifting from a defensible statement to an indefensible one over a few seasons, which is roughly the history of every phrase examined on this site.
If you think a claim is misleading
The Advertising Standards Authority accepts complaints from the public, free of charge, and publishes its rulings. Complaints are more effective when they identify the specific claim, where it appeared, and why the evidence for it appears inadequate. The Competition and Markets Authority has a broader consumer protection remit and has taken an active interest in environmental claims. Local Trading Standards services enforce at a local level, and the Office for Product Safety and Standards handles cosmetics product compliance.
None of these bodies pre approves claims. The system is complaint driven, which is why unsupportable claims persist until somebody objects.
This site names no brands and no products, publishes no rankings and takes no money from anyone selling sun care. It examines claims as claims, which is what makes the analysis transferable: the test above works on any product, including ones this publication has never seen.
Imagery counts as part of the claim
One point that surprises people drafting packaging: the assessment is of the overall impression, not only of the words. A pack showing coral, turtles or a tropical reef, in a category where reef harm is a live public concern, contributes to the impression that the product is being presented as reef beneficial, even where no such words appear. So does a colour scheme and a name that gesture in the same direction.
This is settled practice in advertising assessment across sectors. A claim can be made by implication, and an advertiser holding no evidence for the implied claim is in the same position as one holding no evidence for a stated claim. The practical consequence is that a company which has carefully avoided the phrase reef safe, while covering its packaging in reef imagery, has not avoided anything.
The same logic runs through the natural category more broadly. Botanical illustration, kraft paper, leaf motifs and words such as pure and clean all contribute to an overall impression, and where that impression amounts to a claim about composition or safety, it can be assessed as one.
The broader point
The value of this test is that it separates two things that get conflated: whether a concern is legitimate, and whether a claim is supportable. The concern behind reef safe is legitimate. The claim is not supportable, because it has no criteria. Those are compatible positions, and holding both is the position this publication takes throughout.
It also puts the burden where it belongs. A reader should not have to research marine toxicology to assess a phrase on a bottle. The advertiser has to hold the evidence, and if the phrase is such that no evidence could exist, that is the advertiser's problem rather than the reader's.