Our green credentials.

Defining sustainability.

The dictionary defines "sustainable" as something that is "made in a way that causes little or no damage to the environment and therefore able to continue for a long time". In recent years, this word has become widely used as a way of speaking about environmental impact, with the more specific definition “causing, or made in a way that causes, little or no damage to the environment, and therefore able to continue for a long time.”

This is the definition our customers use, and it’s the definition we use.

This means we don't just focus on one narrow part of making Naked Paper. We monitor and work to reduce our environmental impact across several key areas: our CO2e emissions, our raw materials, and our social impact. We also seek external certification from trusted international bodies and provide proof of our claims, so customers can judge our impact for themselves.

When we say "our factory", we mean LC Paper, our manufacturer in Girona, Spain.

Evidencing our claims - index

Key claims

• Why is toilet paper white?
• It's brown because it's greener
• The UK's most sustainable toilet roll | The UK's most eco friendly toilet roll
• Better for the planet | Gentler on the environment | Loo roll that doesn't cost the earth
• Smaller climate footprint than other eco brands
• No bleach
• No harsh chemicals
• No plastic
• Trees and toilet paper
• The UK's highest rated eco loo roll
• Rated No.1 eco toilet roll by Ethical Consumer
• Carbon cuts, not carbon credits

Product claims

• FSC certified bamboo and recycled materials (C109654)
• Every batch traceable to its supplier
• Food safe certification
• Independently tested for PFAS, none detected – bamboo and recycled loo roll
• Independently tested for BPA, none detected – bamboo and recycled loo roll
• REACH compliance – Europe's strict chemical safety law
• Dispersibility tested every batch (ISO 12625-17)
• Packaging made from 100% recycled material
• Vegan glue
• Water-based ink on our boxes
• Bamboo is grown without any fertilisers or pesticides – Taison and Chengdu Qingya
• Roll Cosy is made at a Fairtrade certified factory, using REACH-compliant inks, in collaboration with Bags of Ethics.

Factory claims

• Factory powered by renewable energy
• Factory with its own solar farm
• A few of the forklifts that move the heaviest reels still run on diesel. LC Paper plan to change these when possible.
• No unnecessary waste
• 8,000 onsite solar panels
• Award winning energy innovations (Tissue World, 2017)
• Water tested every quarter and returned to the river
• Patented system to recirculate heat, reducing energy use significantly
• Highest rated B Corp tissue factory
• ISO 14067 CO2 footprint
• ISO 50001 Energy Savings
• ISO 14001 Environment

Climate footprint / emissions claims

• ISO 14067 lifecycle assessment
• Product climate footprint
• Carbon footprint standard
• CO2e assessed product
• Science based emissions reduction targets (SBTi)

Raw materials claims

• Bamboo
• Recycled

Other claims

• The average person uses 127 toilet rolls per year
• Paper making is traditionally powered by fossil fuels
• Normal toilet paper and household tissue products wipe out nearly 1m trees per day (345m a year)
• Most of the energy in paper making is used to generate the heat that dries the paper (p. 22)
• Normal tissue products can be made using harsh chemicals
• BPA has been found in some paper products, including toilet paper made from recycled paper
• PFAS have been detected in toilet paper sold in several regions of the world
• Price comparison | Best priced eco toilet roll
• How we calculate our savings
• How much paper is saved by not wrapping our rolls
• Printed marketing materials
• Member of Scottish Fair Trade
• Our green claims policy
• Registered trademarks

Why is toilet paper white?

Toilet paper doesn't need to be bright white to do its job. White has long been an established consumer expectation in the mainstream tissue market and has been associated with perceptions of cleanliness.

A US Environmental Protection Agency market study found that mainstream consumers demanded bright white tissue. One tissue manufacturer explained that “clean and sanitary translates to white”, while distributors reported that mainstream consumers perceived unbleached toilet tissue as not looking as “clean” because of its colour.

Naked Paper chooses not to bleach its toilet paper, which is why it retains its natural unbleached colour.

Evidence: U.S. Environmental Protection Agency (1992), Market Study of Molecular Chlorine-Free and Totally Chlorine-Free Bleached Paper, Chapter 4, pp. 4-18–4-19. View the evidence.

It's brown because it's greener.

Most conventional tissue is bleached, a process that requires extra chemicals, energy and water. Our LCA shows that by skipping this step, our unbleached rolls have a lower climate footprint than standard white tissue. That’s why we describe them as kinder to the planet. Or as we like to say: We didn’t make it brown. Nature did.

Bamboo is also different from trees used for virgin wood pulp. When mature bamboo stems are harvested, new stems can grow from the plant's established underground rhizome system. This means bamboo can regenerate after harvesting without ordinarily needing to be replanted each time.

Evidence: FAO, Bamboo Silviculture. View the evidence.

1. Reduced Chemical Pollution

The bleaching of paper, especially using chlorine based chemicals, releases harmful substances like dioxins and furans. Persistent organic pollutants (POPs) that accumulate in the environment and can be toxic to human health. Studies have shown that:

• The bleaching process in kraft pulp mills accounts for 80-90% of the total chemical releases into the environment. (NCASI Report)
• Chlorine bleaching creates toxic byproducts, including dioxins, which both the Environmental Protection Agency (EPA) and the United Nations Environment Programme (UNEP) have identified as serious environmental risks. (EPA) (UNEP)
• Scientific research shows that Elemental Chlorine Free (ECF) and Totally Chlorine Free (TCF) bleaching methods reduce pollutants but do not eliminate them entirely. (Confederation of Paper Industries)
• Dioxins and furans from chlorine bleaching are among the most toxic environmental pollutants, according to studies published in Environmental Science & Technology and PubMed. (Environmental Science & Technology Study) (PubMed Study)

By manufacturing our unbleached tissue products, we avoid introducing these harmful chemicals into waterways and ecosystems.

2. Lower Energy and Water Consumption

Bleaching requires additional energy and water to remove lignin, the natural component that makes paper brown. Research indicates that:

• A Life Cycle Assessment of toilet paper production found that the bleaching process significantly increases energy and water consumption. (LCA Study)
• The bleaching process adds significantly to the climate footprint of both ECF and TCF bleached pulp products. (Environmental systems analysis)
• Reducing or eliminating bleaching in tissue production lowers the overall environmental impact, conserving valuable resources like water and energy.

3. Biodegradation

Naked Paper toilet paper and packaging is made from biodegradable materials (Biodegradability report).

• Studies on paper biodegradation rates show that unbleached paper releases less CO₂ as it decomposes, indicating a more environmentally friendly breakdown process. (Waste Management Research Study)

The UK's most sustainable toilet roll

We have used the claim “The UK’s most sustainable toilet roll.” The comparison below is evidence for it.

Where we have used phrases such as "best eco loo roll," "best sustainable loo roll," "better for the planet," "gentler on the environment," "greener," "loo roll that doesn't cost the earth" or similar, we mean being a more sustainable choice than other eco toilet roll brands, as evidenced in the below tables. This also applies when we have said our paper is "made better - for the planet, for everyone."

When we use these phrases to compare Naked Paper with conventional loo roll made from virgin wood, we mean that our loo roll has a lower climate footprint than typical virgin wood loo roll made in the UK (see our data comparison and how we calculate our savings), is unbleached (see No bleach), and is made from bamboo or recycled cardboard and kraft paper, so no trees are cut down to make it (see Trees and toilet paper).

Our commitment to sustainability is reflected in every part of our process, from reducing chemical pollution and lowering energy and water consumption to ensuring our products biodegrade efficiently. It’s why we call our products "uncompromisingly sustainable paper", because we don’t cut corners when it comes to protecting the environment and creating a truly sustainable alternative.

The claim "best toilet paper delivery" is also evidenced in the below table.

No bleach.

At Naked Paper we do not bleach our rolls in any way. We do not use any bleaching method, including Elemental Chlorine Bleaching, Elemental Chlorine Free (ECF) bleaching or Totally Chlorine Free (TCF) methods.

The Cambridge Dictionary defines “bleach” as “to remove the colour from something or make it lighter, with the use of chemicals or by the effect of light from the sun”. So any process used to whiten paper is bleaching, including chlorine-free methods such as hydrogen peroxide or ozone. When we say unbleached, we mean no bleaching process is used to whiten our paper.

Most conventional white toilet tissue is whitened during manufacture using bleaching processes. You can read more about why white became an established consumer expectation in our Why is toilet paper white? section.

Our factory, LC Paper, confirms that no chlorine, peroxide, ozone or optical brighteners are used in making our paper. Our loo roll has also been independently tested for chlorine bleach, and our loo roll and kitchen roll are ISEGA food safe certified.

Carbon cuts, not credits.

When it comes to addressing the climate crisis, we agree with Greenpeace and the World Wildlife Fund, offsetting isn’t going to cut it. We don’t offset or purchase carbon credits at Naked Paper. We calculate our climate footprint so that we can actually reduce it.

Water-based ink on our boxes.

We print our boxes using water-based inks. Evidence here.

No unnecessary waste.

We're committed to minimising waste at every stage of our process, ensuring that resources are used efficiently and responsibly.

Efficient Resource Use

Our unbleached loo roll avoids harsh chemicals like bleach, formaldehyde, BPA, and PFAS, reducing the need for additional processing and unnecessary resource consumption. We use waste cardboard and kraft paper to produce our recycled toilet rolls, reducing reliance on virgin materials and promoting a circular economy.

Recycling & Reuse

Any imperfect rolls or damaged boxes are not wasted - they are reintegrated into our production process, ensuring materials are continually reused rather than discarded. Our packaging is plastic-free, tape-free, and fully recyclable, eliminating unnecessary materials and making disposal simple and sustainable.

Sustainable Manufacturing

Our factory is powered by renewable energy, including its own solar farm, significantly lowering our climate footprint.
The water used in our production process is treated and tested every quarter to make sure it meets strict quality limits before it's returned to the river Fluvià. By focusing on waste reduction, recycling, and responsible resource use, Naked Paper ensures our products are as sustainable as possible.

Water returned to river.

The water from our factory is treated and tested every quarter to make sure it meets strict quality limits before it's returned to the river Fluvià, in Northern Spain.

How do we know this? Every quarter, our factory conducts a water analysis to ensure water quality parameters remain within a permitted range, based on the water's average conditions. This means water is tested before it enters the factory, and after it has left the factory premises, and the two samples are compared to make sure there has not been a degradation in any of the environmental parameters measured. Here is an example of the analysis.

Science based emissions reduction targets (SBTi)

The Science Based Targets initiative (SBTi) is a global partnership bringing together CDP, the United Nations Global Compact, the World Resources Institute and the World Wildlife Fund.

They create models that show practical changes companies can make to reduce emissions, in line with the best climate science. Then they lend this understanding to companies like Naked Paper, providing technical assistance that addresses all aspects of our operations, so we know the most effective ways to reduce our impact.

Naked Paper has approved near and long-term science-based emissions reduction targets with the SBTi. We have a clear path -with targets that are assessed and validated, and guidance on the best way forward. The SBTi has verified Naked Paper’s net-zero science-based target by 2040.

Naked Paper is registered on the SBTi website here.

Paper savings calculation for unwrapped rolls.

When calculating the amount of paper saved when you buy toilet rolls that have not been individually wrapped, we have measured the sheets of paper used by Who Gives a Crap to wrap their rolls (27.5cm x 42cm). We've multiplied the length of this sheet (42cm) by the average household size of 2.4 people, and an average annual usage of 127 rolls per person per year, which comes to a length of 128 metres of paper, taller than Big Ben, at 96m.

Printed marketing materials.

We aim to minimise the use of physical materials as much as possible in our marketing. When printed materials are required, we ensure 100% recycled and recyclable materials are used. Our printing partners of choice are Seacourt and Jump, both of whom utilise a VOC-free printing process. Their factories are zero waste, and run on renewable energy as far as possible.

Our green claims policy.

Naked Paper is committed to transparency and authenticity in every environmental (or “green”) claim we make. To support this commitment, we have a Green Claims Policy in place that sets out the standards we expect all communications to meet. The full policy document is here.

Our policy aligns with the requirements of relevant laws and regulations and meets the standards of recognised frameworks, including the UK Competition and Markets Authority’s Green Claims Code and the Anti-Greenwash Charter.

Our Green Claims Policy applies whenever we communicate publicly about the environmental benefits of Naked Paper. This includes all words and images used on our website, packaging, social media channels, and in any advertising or other public communications.

To ensure ongoing compliance, we participate in Campaign Reviews conducted by the Anti-Greenwash Charter. These reviews assess our marketing and communications campaigns against our Green Claims Policy, verifying that all claims are evidence-backed and responsibly communicated.

Governance of this policy.

Our founders are responsible for making sure that our compliance with our Green Claims Policy is understood and adhered to throughout our business. Any published communications not compliant with the policy will be corrected and raised with our leadership team.

All Naked Paper staff are trained in the importance of this policy and how to follow it. Prior to publication any materials containing green claims are checked by a member of the team responsible for Green Claims Policy compliance, and these checks are recorded.

Simple training materials are available for new staff to review during training and at any point after, and we also share these materials with third parties such as suppliers and partner companies.

Escalation.

If you have any questions or concerns regarding our environmental communications, or if you believe we are not adhering to our standards, please tell us. You can reach us via email at hello@nakedpaper.com.

Alternatively, you can submit any greenwashing concerns directly to the Anti-Greenwash Charter for an independent review here.

Registered trademarks.

• Naked Sprout® – UK00003514519
• Naked Paper® – UK00004094971
• Naked Roll® – UK00003958369
• So green it’s brown® – UK00003920055
• It’s brown because it’s greener® – UK00004135062
• We didn’t make it brown. Nature did® – UK00004250954
• As nature intended® – UK00004250949