PACKAGING STANDARDS COUNCIL REPORT APRIL 1995
1. Excessive packaging of 'Always Ultra' sanitary
2. Packaging of Hewlett Packard print cartridge
3. Labels lost from 'Supercook' baking powder and other products
4. Excessive packaging of 'Pepcid AC' anti-acid tablets
5. Excessive packaging of 'Aqua Fresh Flex' toothbrush
6. Excessive packaging of L'oreal 'Plenitude Action Liposomes' and other cosmetics
7. Excessive and difficult to open packaging of 'Flymo' replacement lawnmower blades
8. Outer carton on Boots 'Mediclear' skin wash unnecessary
9. Cussons Imperial Leather shower gel packaging ‘misleading’ and excessive
10. 'Elaborate and unnecessary' packaging of Weight Watchers/Heinz cookies
11. Excessive 'packaging' of Postage Stamps
1. EXCESSIVE PACKAGING OF 'ALWAYS ULTRA' SANITARY TOWELS
That the packaging of 'Always Ultra' sanitary towels (manufactured by Procter & Gamble) is
excessive in that the towels are individually wrapped.
In this case the PSC did not seek a response from the manufacturer. The Council's own research
indicates that sanitary towels are often taken from the outer pack in ones and twos and
transferred to a handbag for later use. The individual wrapping then provides a way of keeping
the towel clean and also discreet in appearance. Were such towels only used in the purchaser's
own bathroom, then it is possible that the individual wrappings might not be necessary.
However, this seems to be rarely the case. In the PSC's view, therefore, the packaging
complained of complies with the test of meeting consumer needs with the least possible impact
on the environment and the complaint is unjustified.
2. PACKAGING OF HEWLETT PACKARD PRINT CARTRIDGE
That the packaging of ink-jet print cartridges supplied by Hewlett Packard for use with its
printers is excessive.
When the PSC approached Hewlett Packard in the UK on this issue, the company pointed out
that the product is manufactured in the USA and that changes designed to reduce the amount of
packaging were already underway. The original packaging that prompted the complaint consisted
of an aluminium tray with polystyrene cup and lid to contain the cartridge plus a large outer box
and a large insert with printed instructions for loading the cartridge. This has now been replaced
with a smaller box, a wrapper to prevent moisture loss from the cartridge during shelf life, an
inner liner to prevent the cartridge puncturing the box and a smaller instruction insert. There has
been a total reduction of 37% in the mass of materials used for packaging. The new packaging
also makes much greater use of recycled materials.
The PSC welcomes the fact that Hewlett Packard was already taking action to reduce the
packaging of this product (which in the Council's view was excessive).
3. LABELS LOST FROM 'SUPERCOOK' BAKING POWDER AND OTHER
That the outer sleeve labelling on 'Supercook' tubs of baking powder tears when the tamper-
evident seal is broken in such a way that the complete sleeve becomes detached, resulting in a
loss of product identification and instructions for use.
The Brandway Group, which manufactures 'Supercook' products, replied initially that the sleeve
labelling is partially glued on the inner surface so that when it is heat shrunk on to the tub, the
glue is activated. It suggested that in an isolated case, the glue had not been activated. Research
by the PSC, however, showed that loss of the whole label was a common occurrence.
Subsequently, Brandway stated that it was investigating new designs of perforation that would
ensure a clean tear, maintaining the tamper-evident security and also ensuring the label remained
firmly fixed to the product. Samples of its developments were supplied to the PSC.
The Council welcomes Brandway's continuing efforts to improve the design of perforations. It is
the Council's view that the label design complained off was ineffective in that loss of the whole
label was almost inevitable. New perforation designs tested by the PSC worked more effectively.
The PSC understands that further refinements to the design of the perforations are now to be
introduced and welcomes Brandway's commitment to improving its packaging.
4. EXCESSIVE PACKAGING OF 'PEPCID AC' ANTI-ACID TABLETS
That the packaging of 'Pepcid AC' anti-acid tablets is excessive in that the package containing 6
tablets is over large and the blister pack contains excessive space around each tablet.
'Pepcid' tablets are distributed by Centra Health Care, part of the Johnson & Johnson group. Like
all pharmaceuticals, anti-acid tablets are subject to control by the Medicines Control Agency.
The MCA requires certain information to be included on the packaging and in the case of
'Pepcid' tablets this requirement actually dictates the size of the packaging. Centra has informed
the PSC that it has taken a number of measures to ensure the packaging is no larger than required
by the need to print instructions for use. It has, for example, placed the bar code on the side
rather than the back of the pack. Centra believes it would be difficult to reduce the size of print
used for the instructions without losing legibility. Centra also points out that the pack sizes for 6
and 12 tablets are very little different - again because the size is governed by the instructions for
use - but it makes very clear on each pack the number of tablets contained.
The Council has received a number of complaints about pharmaceutical products in the past. It
is clear that such products need to comply with strict regulations and that these requirements
can restrict the flexibility of packaging design. The PSC believes that effective control and
regulation of pharmaceutical products sold to the general public is of paramount importance.
While a number of companies have been able to respond to concerns raised by the PSC within
the existing regulations, the Council realises that this may not always be possible.
5. EXCESSIVE PACKAGING OF 'AQUA FRESH FLEX' TOOTHBRUSH
That the plastic box housing the 'Aqua Fresh Flex' toothbrush is unnecessary and excessive,
particularly as the box is further wrapped in a cellophane overwrap.
The 'Aqua Fresh Flex' toothbrush is manufactured by SmithKline Beecham. SKB points out that
the plastic box has several purposes - it protects the toothbrush during transit from the
manufacturer in Germany and may also be used by consumers to store the toothbrush when
travelling (the original complainant thought this an unnecessary use). The cellophane overwrap,
according to SKB, provides tamper evidence and also printing, since current technology does not
allow printing to be done directly onto the plastic box. SKB, however, agreed with comments
from the PSC that its testing has shown that the 'tear tape' on the overlap, which allows the
cellophane to be easily removed, was hard to distinguish and should be produced in a different
colour to the main wrap. SKB welcomed the comments from the Council and while it believed
that this particular product was meeting consumer needs stressed its commitment to reducing
The PSC believes that what might appear as excessive packaging to some consumers - in this
case the plastic toothbrush box - may have a value to others, ie an additional use while
travelling. Certainly this is the view held by SmithKline Beecham. It seems unlikely that SKB
would persevere with the added expense of producing the plastic box if it were not confident that
consumers in the main perceived this as a benefit. The Council is of the opinion that where
packaging can usefully perform a dual purpose - protection in transit and some perceived benefit
to the consumer - both these needs must be considered in assessing the packaging, which in this
case is not regarded as excessive.
6. EXCESSIVE PACKAGING OF L'OREAL 'PLENITUDE ACTION LIPOSOMES'
AND OTHER COSMETICS
That L'Oreal 'Plenitude' products and other cosmetic goods are excessively packaged.
This is largely a generic complaint and an example of many that the PSC receives. The Council
must be particularly careful about complaints of 'overpackaging' in the cosmetics sector. Many
products in this area fall into the category of gift products, where the packaging and general
presentation is almost as important as the product itself. The PSC recognises this and is wary of
taking a very strong line in an area where consumers obviously wish the packaging of products
to represent the intrinsic or perceived value of the goods. However, in the case of L'Oreal
'Plenitude Action Liposomes', the Council was concerned at the amount of void space around the
jar containing the product. The height of the plastic moulding which supported the jar, and hence
also the carton - was about twice that of the jar. The Council considers this excessive and
possibly even misleading. When contacted by the PSC, L'Oreal commented that in 1992 it had
begun a systematic review of all its packaging components and design and has installed a
computer system to evaluate the maximum environmental benefit and practicalities required of
each pack. One of the first products to be reviewed under this system was 'Plenitude Action
Liposomes'. The PSC can confirm that the new packaging - replacing the original complained of
- does represent a considerable improvement.
Packaging is a flexible rather than static component in most industries. Indeed, packaging offers
a very flexible way for manufacturers and retailers to attain a number of objectives - for
example, increasing market share, redefining the market for a product and cutting costs. Often,
as in this case, the packaging type complained of has been replaced. The PSC is particularly
pleased that in this example L'Oreal has gone to considerable trouble and cost to install a system
to evaluate its packaging on an environmental and practical basis as well as its cost and
7. EXCESSIVE AND DIFFICULT TO OPEN PACKAGING OF 'FLYMO'
REPLACEMENT LAWNMOWER BLADES
That the rigid 'blister pack' used for 'Flymo' replacement lawnmower blades is excessive,
difficult to open and the product hard to remove.
The Flymo company produced a detailed response to PSC follow-up of this complaint. In
essence, the company argued that its current packaging policy was the result of 20 years
experience and that it believed it met all the major criteria demanded by retailers and consumers
as well as the manufacturer's need to protect the product in transit and storage. Flymo undertook
to review some recommendations made by the PSC following evaluation of the packaging and
also expressed interest in the PSC's Code of Practice on packaging, requesting a number of
copies for internal distribution.
Generally, the PSC welcomes Flymo's approach to packaging, believing that overall its
packaging systems are well conceived. However, the Council believes that in the particular
product complained of the instructions for opening could be made clearer and more effective and
that, in particular, the symbol showing where to open the packaging, while complying with
current requirements, could be larger and more prominently displayed. Subsequent to the
correspondence on this complaint, Flymo provided an example of its new packaging for
replacement plastic cutters which achieved nearly a 50% reduction. The PSC welcomes this
8. OUTER CARTON ON BOOTS 'MEDICLEAR' SKIN WASH UNNECESSARY
That the outer carton containing Boots 'Mediclear' anti-bacterial skin wash is unnecessary and
excessive since all instructions and tamper evident security are on the bottle itself.
Boots has responded to PSC enquiries on this product by saying that the entire 'Mediclear' range
has recently been re-packaged as a result of the company's Packaging Audit initiative (recently
commended in the 1994 RSA Environmental Management Awards). As a result of the audit, the
outer cartons have been removed from all 8 products in the range - a saving of nearly 5 tonnes of
carton board each year.
The PSC takes great delight when packaging issues raised with it by consumers turn out to have
been already addressed by organisations as part of their own growing commitment to
responsible and effective packaging. Boots is generally well known as a company committed to
good packaging policy and the Council is pleased that in this regard (as with some other
examples in this Report) action had been taken without the need for the PSC to press for change.
9. CUSSONS IMPERIAL LEATHER SHOWER GEL PACKAGING ‘MISLEADING’
That the Imperial Leather shower gel packaging is misleading, in that the detachable top (used
for hanging the product in the shower) gives an impression of greater size to the container and as
a result wastes resources.
Cussons argues that the design of the shower gel bottle is not deceitful and that while it does
require a 'fair amount of plastic' this is a result of providing a functional benefit to customers. In
particular, Cussons wished to respond to consumer research showing that the hook element of
the bottle, used to hang the gel bottle in the shower, needed to work more effectively and also,
according to research, needed to be 'self evident' to consumers on store shelves. The same shaped
packaging is used for a range of Cussons brands. Cussons adds, however, that it believes the
amount of plastic used in the packaging can be reduced without affecting its performance and
tests are underway. The results could reach the marketplace by late 1995/mid 1996.
The PSC concludes that to some consumers the overall pack presentation could give the
impression that it contains a larger quantity of product than it in fact does. However, the
contents are clearly marked and the Cussons product is not noticeably disproportionately large
compared with other similar products. While no doubt achieving its purpose, the current end-
piece hook appears bulky and to use considerable amounts of plastic. However, the Council is
reassured by Cussons' work on reducing resource use and notes that the company has an
established reputation for packaging reduction.
10. 'ELABORATE AND UNNECESSARY' PACKAGING OF WEIGHT
That the packaging of Weight Watchers/Heinz 'stem ginger cookies' is excessive, elaborate and
unnecessary in that the cookies are wrapped in pairs and then collated into an outer carton.
This complaint was not referred directly to the manufacturer, although it was informed of the
complaint and the Council's comments. Council staff undertook their own investigation, taking
the PSC Code of Practice as a guide and using some simple experimental techniques.
The PSC believes that in this case the packaging is neither excessive nor unjustified. The product
is consciously aimed at 'dieters' and as such it must be supposed that the 12 cookies will not all
be consumed once the outer carton is opened. The "Weigh Watchers" portion is 2 cookies.
Wrapping the cookies in pairs in a thin high moisture barrier film is essential to maintaining the
freshness of the product. As a simple test, PSC staff opened one pair of cookies, ate one and left
one unwrapped for 24 hours. This was then compared for taste, texture etc with a cookie taken
from a freshly opened pair. The cookie that had been unwrapped for 24 hours had deteriorated
considerably. Packaging is a system for containing and protecting products and delivering them
to the consumer in an acceptable state. The PSC consistently states that manufacturers are
unlikely to invest in elaborate packaging (and so increase their own costs and end price of the
product) unless they have good reason to do so.
11. EXCESSIVE 'PACKAGING' OF POSTAGE STAMPS
That the cover used for a book of postage stamps weighs more than the stamps themselves.
This complaint was not referred to the Post Office. While the PSC does not believe this is strictly
speaking an issue of packaging, it thinks it worthwhile to put its views on record as it raises
many of the issues involved in more traditional packaging complaints. When stamps are sold in a
Post Office, usually for immediate use, they are sold 'loose' and are taken from a large sheet.
With stamps now being sold from a variety of outlets, often for later use, some method is needed
to protect the stamps (which after all have a reasonably high value) from contamination,
especially by humidity. It is therefore clear that the booklet cover, which admittedly weighs more
than the stamps but has much less 'value', is an essential means of containing and protecting the