Our response to the recent Which? article
Update: October 2024
We approached the experts at the Centre Technique du Papier (CTP) to investigate the findings of our own research following the Which? report. The CTP performed the same test on our products and have confirmed that the bamboo we use looks too similar to hardwood to be able to positively identify it using the staining method of the TAPPI-T 401 test.
They have provided this slide to show the similarity of the long fibres in both samples when viewed under a microscope. After running this assessment their conclusion was that “the quantitative determination of the fibrous composition is impossible to perform.”
We've provided further details of this testing at the end of this post (before the May update).
Update: May 2024
As part of our ongoing research into the test performed by Which? we recently conducted some additional testing using the same method. The results of our most recent testing - on a single roll of toilet paper - were widely inconsistent and support our decision not to rely on TAPPI T 401 testing to verify our supply chain. We’ve provided the details of this testing at the end of this post.
Original post
It's been a challenging week for our team. In their April Edition, Which? published a review of sustainable toilet rolls, where they suggested that our supply chain is not adequately controlled, and our bamboo products are not made from bamboo.
We want to assure all of our customers that we only use bamboo to make Naked Sprout bamboo products, and share this statement from our founder Leila:
"Myself & the team are incredibly disappointed to see the recent article in Which?, suggesting our amazing Naked Sprout bamboo toilet paper isn’t bamboo.
At Naked Sprout we go to significant lengths to ensure what we tell you and what we sell you is the very best – especially in terms of sustainability.
We’re aware the test done by Which? suggests that our bamboo toilet roll doesn’t contain any bamboo. So we wanted to take this opportunity to share a little about the test. And a lot about our methods to ensure our bamboo supply chain is robust.
So let’s start with the test.
There’s no perfect way right now of testing unbleached bamboo toilet paper. We’ve been looking for a test that’s accurate, reliable and implementable within our supply chain for a long time.
The problem is, unbleached bamboo can show very similar properties to softwood and hardwood. This makes visual recognition by the laboratory particularly difficult. Especially when, like us, you don’t bleach your toilet roll.
On the question around the validity and reliability of the test. Some of our competitors are calling it a “cop out” to challenge the results. But even the people that accredit the test admit that it has limitations and say ‘considerable variation in the precision is to be expected’ (source).
We have been reassured to see TAPPI’s recent statement that they would be open to developing a bamboo-specific fibre test and we've contacted their team to start the process of creating a specific peer-reviewed test method to add to their catalogue.
We understand that just because the test is unreliable we shouldn’t expect you to believe us when we say our toilet roll is bamboo.
We know that trust requires evidence.
Therefore, we are moving to a policy of radical transparency. So every one of our customers can see our Forest Stewardship Council (FSCC007915) independently verified, full supply chain data.
This means that you’ll be able to see exactly where our bamboo is grown, exactly how it comes to our factory, and exactly what goes into our products to produce your toilet paper. This will make us the first toilet roll brand to do so.
Over the next few weeks we will make our supply chain data easy to access and easy to understand. But in the meantime, here’s the raw data. We have it, so you should have it too.
We have a full lifecycle analysis of the carbon footprints of our products, in line with ISO14067. You can view this here. We would love for other companies to publish their lifecycle analysis to help consumers make informed choices.
Our factory is a B Corp. As well as ISO50001 compliant so you can trust us when we talk about our energy use. We have rigorous environmental management systems in place in line with ISO14001 and you can see proof of that too.
We strive to ensure independent verification in everything we do. From being a B Corp ourselves, to our supply chain and our production at a B Corp certified factory. At every stage, we at Naked Sprout aim to ensure everything we do is provable.
We will continue to ensure absolute transparency around our green claims & with our customers."
You can read our full response to the Which? article here.
Radical Transparency
Naked Sprout has committed to radical transparency. What is this approach to ethical business, and what will it look like for Naked Sprout?
In business, radical transparency is an open approach to corporate information. Traditionally, businesses have kept their processes carefully guarded in an attempt to gain an advantage over competitors. In contrast, a radically transparent approach assumes that openness, in itself, builds resilience in a company and brings value to its customers and the wider community.
If we were a software developer we'd be publishing our code, if we were a drinks manufacturer we'd be sharing our recipe. At Naked Sprout, we make environmentally friendly toilet rolls, so we're providing the details of the specific forests and recycling depots that our raw materials come from, the way that these raw materials travel, and the CO2e cost of every part of our operations.
In a way, it's what we'd already been doing. The detail that we provided in our Life Cycle Assessment, and the CO2e figures we're using to label our packaging have depended on an ethic of openness and accuracy in our reporting. Now the documentation and information we share with B Corp, the FSC, the Science-Based Targets Initiative and the scientists who carry out our Life Cycle Assessments will be shared with you, as well.
Is there a better raw material we could be using? Is there a different way of transportation? Are there other glues or packing materials we should be aware of? We want to hear it all, and we want our customers and peers in the sustainable business community to be able to have meaningful input. The only way you can judge how well we are doing, and how we can do better, is if you can see everything.
We would love to see other brands in our industry make the same shift, so we can learn from one another's processes, and continue to drive change in our sector.
For now, thank you for hearing us out. If you have any feedback about Naked Sprout, or any questions at all, you can reach us at hello@nakedsprout.uk
Update - October 2024
The Centre Technique du Papier (CTP) is an industrial research and development organisation based on the campus of the University of Grenoble, France. They are a hugely respected authority in applied research, consulting and expertise for the paper industry.
We approached them to investigate the findings of our own research, that there are species of bamboo used in papermaking that look too similar to hardwood to be able to positively identify them using the staining method of the TAPPI-T 401 test.
CTP undertook tests using the equivalent methodology Which? informed us they had used. The first aim of the test was to qualify and quantify the fibres in a sample of Naked Sprout - and if this was not possible - to provide evidence of why it was not possible.
These images show what the bamboo we use to make Naked Sprout looks like, and what hardwood pulp looks like, when tested using this method.
The long fibres present in both samples look exactly the same. After running this assessment their conclusion was that “the quantitative determination of the fibrous composition is impossible to perform.”
There’s another important detail in this report. Here is the up-close view of sheets of a Naked Sprout bamboo toilet roll under the CTP microscope.
The box outlined in black states that unidentifiable fibre is either bamboo or bleached hardwood. Chemical analysis proves that there is no bleach present in Naked Sprout, leaving only one option for that uncertain fibre, bamboo.
The test used for the Which? report has still not been made public or shared with us, but these are the results of the equivalent ISO methodology, performed by the best of the best when it comes to technical paper research, with a simple explanation of the result.
Update - May 2024
As part of our ongoing research into the TAPPI T 401 testing method used by Which?, our legal team sent sheets from a single Naked Sprout bamboo toilet roll to four different laboratories in different countries.
We asked these laboratories to provide percentage calculations of the raw material, using the TAPPI T 401 method. The results varied widely, despite the fact they were all testing the same toilet roll – proving that TAPPI T 401 is not a reliable method for testing our products.
Laboratory Results
Laboratory 1: Stated that the majority of fibres were probably bamboo but that they could not confidently provide a percentage because of problems with identification of the fibres.
Laboratory 2: Stated that the sample was 62.6% bamboo, with the rest of the sample being hardwood.
Laboratory 3: Stated that the sample was 49% bamboo, but reported some possible issues with identification of the fibres.
Laboratory 4: Stated that the sample was a mixture of bamboo and other hardwood but they could not give a percentage because these fibres look too similar under a microscope.
Analysis
- All of the laboratories gave different assessments of fibre content
- All of the laboratories differed in their confidence that the test could produce definitive results on the sample.
- The accepted margin of error given in the TAPPI T 401 testing document is a 3% difference. The results from the laboratories that were willing to provide percentages fall far outside of this difference
- Three of the laboratories highlighted challenges in definitive fibre identification relating to production methods or the similarity of bamboo with other kinds of fibre when examined under a microscope.
Conclusion
The wide range of results from a single toilet roll illustrates that TAPPI T 401 is not a suitable or reliable method for assessing the fibre content in Naked Sprout bamboo products. This supports the decision we made in 2021 when we reviewed our supply chain as part of our move to manufacturing in Europe and decided to adopt a method of supply chain verification similar to the larger suppliers such as Kimberley Clarke.
Historical results of TAPPI T 401 tests on our products have shown a range from 0% to 100% bamboo, with some tests unable to provide a percentage at all. These inconsistencies in test results cannot be explained by changes in materials or manufacturing methods – we haven’t changed how we make Naked Sprout.
You can find the full logs of our supply chain and evidence of our sustainable manufacturing processes on our website.
