Food for thought - Environmental claims in food advertising

Established by the United Nations in 1972, World Environment Day (5 June) is a platform for raising awareness and encouraging action on environmental issues. Indeed, the ASA & CAP have been regulating environmental claims in advertising for nearly as long. And as part of our ongoing Climate Change and Environment project, we've recently turned our attention towards environmental claims in food advertising.

In this spirit, read on for a smorgasbord of advice to help ensure that your advertising for meat, dairy and plant-based products aligns with the ASA’s current position.

Take care with ‘green’ or ‘natural’ imagery

The ASA’s recent consumer research into environmental claims in meat, dairy and plant-based food products indicated that the use of certain ‘green’ or ‘natural’ terminology or visual imagery in advertising contexts could lead to a cascade of associations, evoking strong assumptions about environmental, animal welfare, and health benefits of a brand or product (which may or may not exist).

The ASA recognises that advertisers have a legitimate right to highlight the provenance of their products, by, for example, featuring farmland, animals, or other ‘green’ or ‘natural’ imagery which promotes their products in a positive light. Whilst this can help advertisers cultivate a particular narrative around a product or brand, care should be taken to avoid such ‘storytelling’ going too far, to the extent that it fosters a misleading disconnect between a particular depiction and reality.

Ideally (and where possible or practical) advertising campaigns should be filmed or photographed in the real-world environments which they’re depicting. Where this isn’t feasible, particular care should be taken to avoid exaggerating the nature – either visually or linguistically - of the real-world farming practices and conditions in a way that goes beyond legitimate storytelling. For instance, advertisers must take care not to imply that their products are “free range”, if this is not the case.

Ultimately - and as with all ads - evidence must be held for all claims, direct or implied, written, or visual.

Farming methods matter, too

Related to the above, claims regarding farming standards or marks need to make clear what specific standards apply, and should avoid exaggerating the environmental or animal welfare-related benefits of any particular system. Although industry professionals might understand the difference between terms (for example “outdoor bred” and “outdoor reared”) advertisers must be sure that the consumer ‘take out’ from an ad is clear. For example, the ASA previously found the claim “Red Tractor Pork is high welfare pork” to be problematic, because the ad did not make clear it was a comparative claim with imported pork.

Similarly, marketers should not claim that animals raised organically are better provided for than they are; for example, by claiming that organically farmed animals experience better conditions than non-organically farmed animals if you’re not able to robustly substantiate that claim. What’s more, claiming to use “organic farming” methods alone may not be enough to substantiate claims of a product’s positive environmental benefit.

Although not yet widely used in advertising, 2024 has also seen a shift towards “regenerative farming” practices. Whilst the emergence of apparently more environmentally friendly farming methods is to be lauded, there is currently no legal or universally agreed definition of “regenerative farming”. As such, it can be used in a wide-ranging and open-ended way as a descriptor, likely with various possible interpretations, and with the potential to imbue a range of perceived environmental attributes or benefits across a particular brand or product.

To that end, and so as to avoid misleading consumers, advertisers must take care to avoid overclaiming in this regard, by, for instance, outlining exactly what is entailed within their own “regenerative farming” practices, and by avoiding making any absolute claims for “regenerative farming” – for instance, that it is “nature-friendly” – without holding suitable evidence for such claims. In the meantime, the ASA is working towards offering further guidance around this topic in 2024.

It’s not always easy being Green

The ASA accepts that, in general terms, switching to a more plant-based diet is a way in which consumers can reduce their overall environmental impact; ads which make this point in very general terms are likely to be acceptable. However, the ASA also understands that some plant-based products may contain a combination of ingredients which may have been subject to complex production and transport processes. Accordingly, such products could have a similar (or greater) negative environmental impact than alternative whole-plant ingredients, or in some cases responsibly sourced meat-based alternatives.

To that end, the Code requires that environmental claims about an advertised product are based on its full life cycle; a product’s environmental benefit cannot be assumed. The ASA has previously investigated an advertising campaign for Tesco’s Plant Chef range which made the claim “a little swap is even better for the planet”. However, because the implication that switching to Plant Chef products would positively affect the environment could not be substantiated, the ASA decided that the claim was misleading.

Similarly, advertisers should avoid making any absolute environmental claims for their products which cannot be substantiated and must ensure that they explain the basis of any such claims. The ASA previously upheld complaints about an ad for Alpro plant-based milks, which said “Good for you, good for the planet”, because there was no context provided in the ad with which to interpret what made the product “good for the planet”. For instance, it could refer to a net positive environmental benefit from producing the products featured in the ad – or it might be that the featured products were less detrimental to the environment compared to their dairy equivalents across their lifecycles. Because of this ambiguity, the ASA considered that the ad did not make the basis of this environmental claim clear, and as such, it was misleading.

A word on sustainability

Finally, the ASA urges caution around the use of “sustainable” within a food production context, and particular care should be taken with any absolute “sustainable” claims, unless such claims are supported by a very high level of substantiation. That said, because there are so many metrics by which sustainability can be measured in a food-related context, even advertisers who use it in a conditional way run the risk of misleading consumers if its use is not suitably qualified or substantiated.

Further help & reading

CAP is here to support advertisers of meat, dairy and plant-based products to speak about their environmental initiatives with confidence – and, for what it’s Earth (!) – be sure to check out other environmentally-themed news, advice and resources here

For bespoke advice on any non-broadcast ads, the Copy Advice team is always here to help. A copy of our formal Environmental Guidance can also be found here.

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