Heidi Beatty, Crown Abbey Consultants08.31.22
The lifting of Covid restrictions has allowed us to travel around Europe again…and that created an opportunity to check out the implementation of the so-called ‘Dead Turtle Logo’- a requirement by the European Union to be included on the outside of wet wipes made from plastic. The European Single Use Plastic Directive (SUPD) has now been rolled out by the member states.
The reason I am passionate about this topic is two-fold; I am a self-proclaimed tree-hugger and I think there is an opportunity for the nonwovens industry to use the learnings from the EU for other regions, and I’m particularly thinking of the U.S.
The SUPD came into force for some products, including wet wipes, in July last year – at which point brands and manufacturers were allowed to attach a sticker with the bold red and blue logo, which contains a crossed-out toilet and a dead turtle, to packaging where wipes contained plastic.
The intention of the SUPD is to reduce littering of these products, both on our beaches as well as in our parks and general environment. Unfortunately, used wet wipes have been found in these places, which is a real concern for our ecosystems when they don’t biodegrade.
As of July 2022, the stickers are no longer allowed, and this logo must be incorporated onto the packaging artwork. This SUPD logo has been determined and cannot be modified. It also needs to be on the front face of the product (as seen by the consumer when the pack is on the shelf). There are six different pictograms to choose from, but they are product specific, so all wet wipes should carry the same one – which indicates that the wipes should not be flushed or littered.
The more important piece, in my mind, is that each EU country has its own translation (or translations) – meaning that if your wipe is in Germany, it must have the German translation of “Product Contains Plastic” and if in France, it must be in French, and so on. This of course is quite complex for the industry, and particularly the brands, who don’t typically sell their product in just one country and have multi-lingual packs – for language groupings across the EU.
When I was at Johnson & Johnson, I remember the marketing colleagues being very blasé about an artwork change for a baby wipe… ‘but it’s just one small change, they would cry!’ But for the poor R&D and regulatory team, it meant updating in the region of 40-50 SKUs – each different count and every different language grouping. It’s a huge task!
In addition to that, (here comes the next dreaded topic) Brexit means that the U.K. is no longer part of the EU. It could have chosen to adopt the SUPD, but instead DEFRA put a call out for comments on a U.K. specific SUPD back in November 2021. We have not yet heard the outcome and I strongly suspect they are waiting to see how the implementation goes in Europe, and to learn from it.
Despite that, there is an awful lot happening on the wipes front in the U.K. – especially from the retailers.
Recently, there has been announcement after announcement of different retailers reducing or eliminating plastic from wipes in their stores. Interesting to note that Aldi consumers were quite vocal when Aldi down-counted and switched to bio-based fibers—they were really unhappy. This seemed to be driven by getting less wipes for your money.
But it isn’t just that, the number of places you can take your own packaging to refill food, household cleaners and such is no longer just for the tree-huggers going to the specialty stores. The recycling programs in Tesco’s (initiated by Berry) to take back flexible packaging is also spreading out to other retailers.
Which brings our attention to the point of whether the consumers understand these logos. After all, that is the most important aspect - to change behavior, and to convince those that need it, to dispose of their wet wipes in the trash.
We can find a wealth of examples where the messages appear to be very confusing - Pampers in Germany, for instance, have a green leaf on their pack which says “With Plant Based Fibers,” right next to the dead turtle logo.
We also see the EDANA and INDA “Do Not Flush” logo placed next to the SUPD logo on a product in Spain, which as you can see already has a crossed-out toilet, indicating not to flush. So why are there two symbols saying the same thing?
In Italy and the Netherlands, we found a few examples of brands using half the SUPD logo – just the crossed-out toilet and not the Dead Turtle – this comes from an industry commitment to indicate products that don’t contain plastic, but still shouldn’t be flushed.
Perhaps the most impactful use of the SUPD logo is on the shelf ready trays that some retailers use for wipes – it is front and center and often at eye level. I think this is a good communication tool – but it doesn’t replace adding it to the wipe’s pack!
The U.K. potentially has the biggest opportunity to confuse the consumer. As the dead turtle logo is not a requirement, we see some plastic-containing wipes with the logo and some without. This is then the choice of the brand, but without any harmonization, it becomes a diluted message. In addition, of course, once DEFRA does issue guidance, then there is a potential for yet another set of artwork requirements…which by the way could be different for each of England, Scotland, & Wales! (Northern Ireland is in scope for the SUPD and so should also carry the dead turtle logo).
Given the U.K. retailers are taking such a stand, and with calls from various ministers to ban plastic-containing wipes altogether, the decision from DEFRA may be the slowest to actually impact the shelves.
It is interesting to see though, that in Tesco’s in the U.K., for example, you don’t find wipes with the SUPD logo, but literally in the next aisle, thedisposable menstrual products (tampons, pads, liners) and each have the dead turtle logo on them. So, this whole discussion is very product specific.
Despite the apparent confusion in some areas in the EU, to be clear, the requirements laid out by EDANA are as follows:
The SUPD will be re-assessed and any updates implemented in 2027—which could well open the door for those nonwovens that currently fall under the definition of plastic but do in fact biodegrade. Clearly the dead turtle logo is a blunt tool - it may just be too simplistic. At the heart of it, we are all trying to ensure used wipes don’t end up in the environment. Just because wipes don’t contain plastic, doesn’t mean we won’t see them littered in our parks and on our beaches, impacting our ecosystems.
No one doing a litter pick will know if they are picking up a plastic-containing wipe or a non-plastic wipe, and I think that is a problem. Ultimately, we need to understand if there is a change to consumer behavior due to the SUPD logos, but it will take some more time, and more studies to understand that.
Meanwhile, in the U.S., we already see tentative steps from retailers, with Whole Foods banning plastic bags, and Walmart and Meyer rolling out the Loop refill programs. Even the U.S. government is banning single use food ware items from all national parks as of next year.
As we see from Europe, consumer education is critical – otherwise they will not buy into the brand’s story. Providing clear guidance and explaining any logos used will mean that the consumer will be appreciative of the brand’s transparency and it will help to change behaviors…and to reduce and hopefully prevent wipes being thrown on the ground or into our waterways.
I urge us, as an industry, to continue to innovate both to enhance the consumer experience and to protect our environment. I’m an R&D person, and I’m excited for the future – I’ve been in the industry long enough to know the smart, talented and passionate people we have in all areas of our businesses. But, there isn’t one solution and I don’t think there should be. Time and again, we see when everyone piles behind one idea, it has the opposite effect - unintended consequences and a dilution of innovation. Some brands are embracing the circular economy, which typically means they are polyolefin based, and others are embracing the bio-based fibers approach. But both are moving the needle and both are needed.
Within our industry, we need to keep an open communication, to embrace the people we see in our industry, that are developing the new fibers, the new approaches. It is a tough business, but we need all types of innovation in all types of ways.
And we at Crown Abbey also see that there is a significant shift to local solutions—production, raw materials, litter picking. Being a part of the local community, having the transparency and open communication with the others around us.
I don’t think we have to compromise our products for the environment – I think we must all strive to deliver better options in terms of sustainability and for our consumers.
Crown Abbey is an experineced R&D consultancy helping big and small companies develop and launch new products by helping them identify the best technologies for their needs. www.crownabbey.com
The reason I am passionate about this topic is two-fold; I am a self-proclaimed tree-hugger and I think there is an opportunity for the nonwovens industry to use the learnings from the EU for other regions, and I’m particularly thinking of the U.S.
The SUPD came into force for some products, including wet wipes, in July last year – at which point brands and manufacturers were allowed to attach a sticker with the bold red and blue logo, which contains a crossed-out toilet and a dead turtle, to packaging where wipes contained plastic.
The intention of the SUPD is to reduce littering of these products, both on our beaches as well as in our parks and general environment. Unfortunately, used wet wipes have been found in these places, which is a real concern for our ecosystems when they don’t biodegrade.
As of July 2022, the stickers are no longer allowed, and this logo must be incorporated onto the packaging artwork. This SUPD logo has been determined and cannot be modified. It also needs to be on the front face of the product (as seen by the consumer when the pack is on the shelf). There are six different pictograms to choose from, but they are product specific, so all wet wipes should carry the same one – which indicates that the wipes should not be flushed or littered.
The more important piece, in my mind, is that each EU country has its own translation (or translations) – meaning that if your wipe is in Germany, it must have the German translation of “Product Contains Plastic” and if in France, it must be in French, and so on. This of course is quite complex for the industry, and particularly the brands, who don’t typically sell their product in just one country and have multi-lingual packs – for language groupings across the EU.
When I was at Johnson & Johnson, I remember the marketing colleagues being very blasé about an artwork change for a baby wipe… ‘but it’s just one small change, they would cry!’ But for the poor R&D and regulatory team, it meant updating in the region of 40-50 SKUs – each different count and every different language grouping. It’s a huge task!
In addition to that, (here comes the next dreaded topic) Brexit means that the U.K. is no longer part of the EU. It could have chosen to adopt the SUPD, but instead DEFRA put a call out for comments on a U.K. specific SUPD back in November 2021. We have not yet heard the outcome and I strongly suspect they are waiting to see how the implementation goes in Europe, and to learn from it.
Despite that, there is an awful lot happening on the wipes front in the U.K. – especially from the retailers.
Recently, there has been announcement after announcement of different retailers reducing or eliminating plastic from wipes in their stores. Interesting to note that Aldi consumers were quite vocal when Aldi down-counted and switched to bio-based fibers—they were really unhappy. This seemed to be driven by getting less wipes for your money.
But it isn’t just that, the number of places you can take your own packaging to refill food, household cleaners and such is no longer just for the tree-huggers going to the specialty stores. The recycling programs in Tesco’s (initiated by Berry) to take back flexible packaging is also spreading out to other retailers.
Confusion Concerns
From our whistle-stop tour of Europe, it is interesting to note, that in general, compliance has been pretty good – the logo looks the same across the shelves. However, when we look at several of the countries, including Germany, the Netherlands and Czech Republic, we see examples of the SUPD logo being in English only. Sometimes the additional languages are added near the logo, so they are not hard to find. This is not in alignment with the SUPD requirements.Which brings our attention to the point of whether the consumers understand these logos. After all, that is the most important aspect - to change behavior, and to convince those that need it, to dispose of their wet wipes in the trash.
We can find a wealth of examples where the messages appear to be very confusing - Pampers in Germany, for instance, have a green leaf on their pack which says “With Plant Based Fibers,” right next to the dead turtle logo.
We also see the EDANA and INDA “Do Not Flush” logo placed next to the SUPD logo on a product in Spain, which as you can see already has a crossed-out toilet, indicating not to flush. So why are there two symbols saying the same thing?
In Italy and the Netherlands, we found a few examples of brands using half the SUPD logo – just the crossed-out toilet and not the Dead Turtle – this comes from an industry commitment to indicate products that don’t contain plastic, but still shouldn’t be flushed.
Perhaps the most impactful use of the SUPD logo is on the shelf ready trays that some retailers use for wipes – it is front and center and often at eye level. I think this is a good communication tool – but it doesn’t replace adding it to the wipe’s pack!
The U.K. potentially has the biggest opportunity to confuse the consumer. As the dead turtle logo is not a requirement, we see some plastic-containing wipes with the logo and some without. This is then the choice of the brand, but without any harmonization, it becomes a diluted message. In addition, of course, once DEFRA does issue guidance, then there is a potential for yet another set of artwork requirements…which by the way could be different for each of England, Scotland, & Wales! (Northern Ireland is in scope for the SUPD and so should also carry the dead turtle logo).
Given the U.K. retailers are taking such a stand, and with calls from various ministers to ban plastic-containing wipes altogether, the decision from DEFRA may be the slowest to actually impact the shelves.
It is interesting to see though, that in Tesco’s in the U.K., for example, you don’t find wipes with the SUPD logo, but literally in the next aisle, thedisposable menstrual products (tampons, pads, liners) and each have the dead turtle logo on them. So, this whole discussion is very product specific.
Despite the apparent confusion in some areas in the EU, to be clear, the requirements laid out by EDANA are as follows:
- The SUPD logo, with both the crossed-out toilet and the dead turtle is mandatory in the EU and Northern Ireland.
- The toilet crossed out with a red background (meaning half of the SUPD logo) is an EU industry commitment – for wipes that are not flushable but do contain plastic. The timeline for this rollout is beginning of next year.
The SUPD will be re-assessed and any updates implemented in 2027—which could well open the door for those nonwovens that currently fall under the definition of plastic but do in fact biodegrade. Clearly the dead turtle logo is a blunt tool - it may just be too simplistic. At the heart of it, we are all trying to ensure used wipes don’t end up in the environment. Just because wipes don’t contain plastic, doesn’t mean we won’t see them littered in our parks and on our beaches, impacting our ecosystems.
No one doing a litter pick will know if they are picking up a plastic-containing wipe or a non-plastic wipe, and I think that is a problem. Ultimately, we need to understand if there is a change to consumer behavior due to the SUPD logos, but it will take some more time, and more studies to understand that.
Meanwhile, in the U.S., we already see tentative steps from retailers, with Whole Foods banning plastic bags, and Walmart and Meyer rolling out the Loop refill programs. Even the U.S. government is banning single use food ware items from all national parks as of next year.
As we see from Europe, consumer education is critical – otherwise they will not buy into the brand’s story. Providing clear guidance and explaining any logos used will mean that the consumer will be appreciative of the brand’s transparency and it will help to change behaviors…and to reduce and hopefully prevent wipes being thrown on the ground or into our waterways.
I urge us, as an industry, to continue to innovate both to enhance the consumer experience and to protect our environment. I’m an R&D person, and I’m excited for the future – I’ve been in the industry long enough to know the smart, talented and passionate people we have in all areas of our businesses. But, there isn’t one solution and I don’t think there should be. Time and again, we see when everyone piles behind one idea, it has the opposite effect - unintended consequences and a dilution of innovation. Some brands are embracing the circular economy, which typically means they are polyolefin based, and others are embracing the bio-based fibers approach. But both are moving the needle and both are needed.
Within our industry, we need to keep an open communication, to embrace the people we see in our industry, that are developing the new fibers, the new approaches. It is a tough business, but we need all types of innovation in all types of ways.
And we at Crown Abbey also see that there is a significant shift to local solutions—production, raw materials, litter picking. Being a part of the local community, having the transparency and open communication with the others around us.
I don’t think we have to compromise our products for the environment – I think we must all strive to deliver better options in terms of sustainability and for our consumers.
Crown Abbey is an experineced R&D consultancy helping big and small companies develop and launch new products by helping them identify the best technologies for their needs. www.crownabbey.com
