Background
On 7 April 2025, the Advertising Codes were updated to reflect the revocation and restatement of the Consumer Protection from Unfair Trading Regulations 2008 (CPRs – the legislation from which the majority of the CAP and BCAP rules on misleading advertising derived) by the Unfair Commercial Practices provisions in the Digital Markets, Competition and Consumers Act 2024 (DMCCA). On that date, the wording of a number of the rules in the Advertising Codes was changed to reflect relevant changes introduced by the DMCCA on 6 April 2025. Given the ASA’s assessment of the ad, which formed the subject of this Ruling, was carried out before 7 April 2025 the ASA considered the ad under the wording of the rules that existed prior to 7 April 2025. The Ruling (and references to rules within it) should therefore be read in line with this wording, available here – CAP Code and BCAP Code.
Summary of Council decision:
Three issues were investigated, of which two were Not upheld and one was Upheld.
Ad description
TV ads, an Instagram post, national press ads, and a page from a website, www.letseatbalanced.com, for the Agriculture and Horticulture Development Board’s (AHDB) “Let’s Eat Balanced” campaign, seen between September 2024 and February 2025.
a. The first TV ad featured a voice-over that narrated the preparation of a beef dish and stated, “British beef has all the goodness of that” as the ad cut to an image of green fields. The ad concluded by showing the fields again and on-screen text, underneath a Union Jack, stated, “BRITISH BEEF” and “LET’S EAT BALANCED FROM AHDB”. The voice-over stated, “British beef. Enjoy the goodness”. Superimposed text stated, “A balanced diet and healthy lifestyle are recommended for good health”.
b. The second TV ad, used the same format as ad (a) but was focused on British dairy, and the voice-over narrated the preparation of foods and drinks involved.
c. The third TV ad, used the same format as ad (a) but was focused on British lamb and the voice-over narrated the preparation of a lamb dish.
d. A page on the Let’s Eat Balanced website titled “Food & Farming Standards”. Under the page title, a subheading stated “FOOD AND FARMING STANDARDS BEEF, PORK, LAMB AND DAIRY ARE PRODUCED IN THE UK TO WORLD-CLASS FOOD AND FARMING STANDARDS” which was superimposed over an image of grassy fields. The page featured images of a sheep being fed in a grass field, cows standing in a grass field, the Red Tractor and RSPCA Assured logos, and pigs outside on a churned-up field. The page featured a number of different sections, subheadings included "WE CAN BE PROUD OF THE QUALITY FOOD PRODUCTION IN THE UK", “FOOD AND SAFETY QUALITY", "HORMONES AND ANTIBIOTICS", "ANIMAL HEALTH", "FARMING STANDARDS" and “FROM THE LAND, NOT THE LAB".
e. An Instagram post from the Letseatbalanced account showed a farmer in a field next to a herd of cows. Superimposed text stated, “Come rain or shine. 365 days a year, we make it our mission to provide quality, nutritious food whilst looking after our Great British countryside”. Text in a roundel in the top of the image stated “THE FUTURE OF FARMING” and the caption included “#futureoffarming”.
f. The first national press ad featured, in its top half, an image of green pastures with a headline that stated “GREAT BRITAIN”. In the top left was half a Union Jack with text beneath that stated “BRITISH BEEF”. In the bottom half of the ad, over a pink background with an image of a person eating a beef dish, the headline continued and stated “GREAT BEEF”. Further text beneath stated “British beef not only tastes great, but has a carbon footprint that's half the global average*. Find out more at letseatbalanced.com”. Below that, text stated “LET’S EAT BALANCED FROM AHDB”. The asterisk linked to text that stated “Full lifecycle emissions of CO2 eq [carbon dioxide equivalent] per kg of beef”.
g. The second national press ad featured, in its top half, an image of green pastures with a headline that stated “GOOD FROM”. The bottom half of the ad, over a blue background with an image of a person drinking milk, the headline continued and stated “GRASS TO GLASS”. Further text beneath stated “British milk not only tastes good, but is also produced to world-class standards, and has a carbon footprint a third lower than the global average”. Beneath was a URL for the Let’s Eat Balanced website and text stated “LET’S EAT BALANCED FROM AHDB”. A footnote at the bottom of the ad stated “Full lifecycle emissions of CO2 eq [carbon dioxide equivalent] per kg of milk”.
Issue
TV presenter and environmental campaigner, Chris Packham, challenged whether:
1. The ads were misleading as they did not reflect the full environmental impact of British meat and dairy;
2. the claim “British beef [...] has a carbon footprint that's half the global average” in ad (f) and “British milk [...] has a carbon footprint a third lower than the global average” in ad (g) were misleading and could be substantiated; and
3. ads (a), (b) and (d), misleadingly implied that cows used to produce beef and milk in the UK were typically outdoor grazed.
Response
The Agriculture and Horticulture Development Board t/a AHDB said they were a non-departmental public body, sponsored by the Department for Environmental, Food and Rural Affairs (Defra), and they supported their levy payers across the food and farming supply chain.
The Let's Eat Balanced campaign was intended to address consumer misconceptions about red meat and dairy produced in Britain and to highlight the role they could play in a balanced diet. This was due to them acting as a natural source of nutrients such as iron, zinc, calcium, iodine, and vitamin B12. AHDB acknowledged human and environmental health was multifaceted, with understandings and standards changing over time, and that a consensus was not necessarily held. It was not a matter of pitting one food or farming system against another, and the ads did not attempt to recommend total or absolute food system changes.
AHDB said the British Nutritional Foundation (BNF) outlined diets that were truly healthier and sustainable and which needed to consider not only good nutrition and lower environmental impact but also the right balance of foods and drinks that were affordable and culturally acceptable. They said the BNF concluded that while a plant rich diet was an aim everyone should aspire towards, that did not mean cutting out animal foods. The BNF outlined that a diet more in line with the Eatwell Guide was likely to have both environmental and health benefits that could facilitate eating in a more sustainable manner. The BNF highlighted, when making remarks regarding future research and policy in this area, that the methods used to assess the environmental impact of foods, such as life cycle assessments, could be improved in general by taking into account the nutrient content and overall nutritional contribution of the foods in a person’s diet. For AHDB, that was because the overall context of beef, lamb, and dairy production in Britain needed to be accounted for. For example, the latest figures (2024) from Defra showed, despite 69% of UK countryside being farmland, 56% of it was permanent grassland or rough grazing which was unsuitable for growing crops or other foods, making raising cattle and sheep for meat and milk the optimal use of that land. Additionally, grazing grassland had the potential to remove and sequester carbon due to the cycling of manure and nutrients while also altering the soil microbial community, enhancing the availability of substrate favouring carbon sequestration. Ruminant livestock were also capable of managing and enhancing habitats while turning grassland, including marginal land, into nutritious protein as part of a circular system of production.
1. AHDB said the primary focus of ads (a) – (c) was to highlight the nutritional value and origin of British beef, lamb, and dairy, and they were a natural source of nutrients that could be enjoyed as part of a balanced diet alongside a healthy lifestyle. Each ad featured a scene of a typical British field used for grazing livestock, indicating the provenance of lamb, beef, and dairy, and were health focused. They did not consider the ads made any environmental claims. and material information in relation to the environmental impact of British beef, lamb, and dairy had not been omitted.
AHDB disputed that webpage (d) was an ad falling within the scope of the CAP Code. AHDB itself did not sell products, and the page did not include a direct call to action or name any retailers of farm produce or products, or provide prices or links to retailers. The page provided educational and news content. Even if the page were to be treated as an ad within scope, the overall impression of the page was that meat and dairy were produced in different ways across the globe and that British beef, lamb, and dairy farmers produced food against some of the most stringent regulations and standards. The reference to "WORLD-CLASS" standards in the page's headline was defined in relation to "some of the highest", which the page also referred to, rather than meaning the absolute best globally. The page defined that ranking in terms of food standards, animal health, production systems, and farm assurance, which were areas broadly understood by consumers to relate to food and farming standards. The imagery used in the page indicated the products were made in Britain and had been produced naturally, reinforced by the "FROM THE LAND, NOT THE LAB" section of the page. Resultingly, the page did not convey misleading environmental information. AHDB explained that the references to the assurance schemes in the webpage (d) were included to provide reassurance to consumers on traceability, production standards, and care for the environment and wildlife. The page had described the schemes in a general manner and had made clear such schemes operated alongside legislation. The page had not suggested any single scheme operated across all areas, or that a scheme guaranteed compliance with environmental law, or delivered absolute positive environmental outcomes. Instead, the schemes provided oversight and verification. The page's framing had not made a precise claim about the performance of any one scheme or made a comparison between them. The references to Red Tractor and RSPCA Assured (The Royal Society For The Prevention Of Cruelty To Animals) were as examples only and were not exclusive or absolute references. AHDB understood there were at least 12 recognised assurance schemes operating in the UK, with 10 having direct coverage of environmental standards. Those 10 schemes focused on risk mitigation and prevention rather than guaranteeing a specific environmental outcome. Therefore, farmers who complied with those standards would show greater care for the environment than a farmer who did not. Red Tractor's work focused on food safety, animal welfare, hygiene, and environmental protection. Regarding the latter, their standards included (non-exhaustively) pollution prevention via fuel, agrochemical, fertilisers, manure, slurry silage, and waste being stored and managed to minimise contamination or spillage risks. RSPCA Assured focused on animal welfare, and any environmental benefits arose indirectly from their focus on welfare, such as pasture access or enrichment which could be associated with providing individual animals with more space.
AHDB also disputed that the Instagram post (e) fell within the scope of the Code, for the same reasons as webpage (d). Even if post (e) did fall within scope, it gave a personal account of a farmer and the work they were doing to produce beef and crops naturally on their farm. It was not an environmental post, and the imagery was typical of British farmland. The farmer's efforts were framed as part of a continuous process, suggesting a commitment rather than perfection. The call to 'like’ the post to support farmers similar to the one featured in the post invited interaction to keep the message open, rather than pushing a singular narrative. They considered post (e) was limited by time and space, and they had provided more detailed information on their Let’s Eat Balanced website that was one click away. By focusing on the story of an individual farmer, post (e) would not mislead consumers.
They said ads (f) and (g) made specific, clear, and comparative claims between the carbon footprint of British beef or milk to the global average and footnoted to a source supporting the claims. Due to the ads’ space constraints more detailed information was set out on the Let’s Eat Balanced website, to which the ads referred. The images of the fields were intended to convey British provenance, serving as generic representations of rural Britain. There were no suggestions livestock raised in pastures were environmentally preferable to other forms of livestock rearing, such as intensive or housed systems.
Across the ads, AHDB said their approach was intended to provide a balanced and evidence-based discussion, reflecting on both the challenges and opportunities in livestock production. They did not intend to speak in absolute terms, instead they intended to acknowledge the journey British agriculture was on. They acknowledged that all food production, including meat and dairy, had an environmental impact, and maintained that the ads had not omitted that information. Their aim was to foster an informed conversation around cattle and sheep farming, recognising both the need for improvement and the role those farming systems could play in shaping the future of food production.
2. AHDB said that the ads’ comparison of carbon emissions would be understood in relation to the environmental impact that occurred between the cradle-to-retail stages of producing beef and milk only, and not in relation to their full life-cycle emissions, and late in the investigation produced the results of a consumer survey which they said supported that interpretation. In the context of agricultural life-cycle assessments, it was standard and technically accurate to describe cradle-to-retail emissions per kg of product as “full life-cycle emissions” as all relevant processes up until the retail stage had been included. “Full” referred to the completeness within the cradle-to-retail boundary and not in relation to the full, cradle-to-disposal, life-cycle emissions of beef and milk. The claims regarding the carbon footprint of British beef and dairy in comparison to the global average were supported by a meta-analysis and a 2020 report, the latter, which the ad footnoted to, drew from the meta-analysis. The meta-analysis outlined the global average environmental impact of a variety of foodstuffs, including beef and milk. The 2020 report used data from the meta-analysis to outline the average impact of beef and milk from Britain.
3. AHDB said the ads showed typical British fields used for grazing either beef or dairy cattle in the UK. Those scenes helped to indicate the products were of British provenance. They said a government survey outlined that beef and dairy cattle spent most of their time grazing outside with access to housing and able to move inside for health or welfare reasons. The ads did not suggest that, in terms of access to outdoor space, all cattle in the UK were kept in similar conditions.
1. & 3. Clearcast said the overall impression of ads (a) – (c) was to promote British produce. The ads focused on highlighting the nutritional value and origin of British beef, dairy, and lamb. They did not perceive any environmental claims or references to environmental impact within the ads. The voice-over's reference to "the goodness of that", while an image of cows in a pasture or a field was shown, was a reference to general welfare and consumer preference, as many consumers, for ethical or quality reasons, wanted to understand the origin of their meat and dairy. They said the imagery of the pastures and fields were minor and brief within the scope and context of the ads, which focused on cooking and nutrition.
Assessment
1. Not upheld
The CAP and BCAP Codes stated marketing communications must not mislead by omitting material information. They also stated the basis of environmental claims must be clear.
The ASA considered consumers were unlikely to be fully aware of how and to what extent livestock farming could positively and negatively impact the environment. We assessed the ads in that context.
We assessed ads (a), (b) and (c). They focused on British beef, dairy and lamb respectively, and featured a voice-over that narrated the preparation of dishes using each ingredient and imagery of grassy fields and pastures. The voice-over stated, "British Beef/lamb/dairy has all the goodness of that". The voice-over then gave the respective nutritional properties of each food. They concluded by showing green fields while on-screen text, underneath a Union Jack, stated "BRITISH BEEF/DAIRY/LAMB" and "LET'S EAT BALANCED FROM AHDB". We considered the overall impression of each ad was that British beef, dairy and lamb respectively were typically produced within the UK and they had various nutritional benefits, which added to a balanced diet. The imagery of grassy fields and pastures in that context were likely to be understood as offering a generic indication that the foods were typically sourced from the natural environment associated with rural areas in the UK and derived benefits from that, including taste or nutritional benefits. The ads were concerned with the provenance, and nutritional properties of British livestock. Viewers were unlikely to infer an environmental benefit.
We considered that webpage (d) did fall within the scope of the CAP Code, which included “Advertisements and other marketing communications by or from […] organisations […] on their own websites, or in other non-paid-for space online under their control, that are directly connected with the supply or transfer of goods, services […]”. The page appeared on AHDB’s Let’s Eat Balanced website, a dedicated website to support AHDB’s Let’s Eat Balanced marketing campaign to support British farming and drive sales of farmed produce, of which paid for TV ads (a), (b), (c) and press ads (f) and (g) were examples. The website was a mixture of content that might be described as educational/editorial and content that might be described as marketing, or a mix of the two. Under the heading “LET’S EAT BALANCED”, webpage (d) was titled “Food & Farming Standards BEEF, PORK, LAMB AND DAIRY ARE PRODUCED IN THE UK TO WORLD-CLASS FOOD AND FARMING STANDARDS". It featured sections on the quality of British food production and its safety; the illegality in the UK of the use of hormone and antibiotics to boost animal growth: referenced the ways animal health was supported; and described the amount of access to the outdoors cattle, sheep and pigs had. Under a section titled “FARMING STANDARDS”, text stated, “While legislation ensures minimum required standards on every farm in Britain, it is underpinned by assurance schemes, such as Red Tractor and RSPCA Assured” and “Assurance schemes bring shoppers confidence in knowing the food they buy has been checked from farm to pack. This includes certifying traceability (or what farm it came from), high production standards and care for our environment and wildlife” and next to that were images of the Red Tractor and RSPCA Assured logos. Further text stated, “Standards implemented by Red Tractor, the UK’s largest food and farming scheme, are world leading in their breadth and depth, spanning every stage of the production process”. The page concluded with a further call to action “LET’S EAT BALANCED”. We considered the page invited readers, as “shoppers”, to look for British farm produce bearing the Red Tractor and RSPCA logos, and as such was directly connected with the supply of goods.
That did not, however. mean that the page was misleading. The average consumer was likely to understand from the ad as a whole that British food was subject to high quality standards that encapsulated all areas of production. That included but was not limited to ‘care for our environment’ within farming methodology. It was explained that schemes such as Red Tractor and RSPCA Assured underpinned the relevant farming legislation to give consumers confidence that the food they bought had been checked at every stage. The ad did not make a more categorical claim (such as “all our standards are met”) and was in a less impactful medium than for example a TV ad. While ‘environmental care’ was captured in the standards of British farming, the reference in the ad’s context was likely to be understood as meaning standards were in place to mitigate against some of the environmental impacts of farming practices. The ad made no guarantees about the extent of the care, and the average consumer was likely to understand that the references to the specific schemes mentioned were merely as recognisable examples of the many organisations supporting the British food chain in different areas of farming practice such as traceability, production standards and or the environment, each with their own particular focuses and levels of commitment.
Instagram post (e) from the AHDB account also bore the “LET’S EAT BALANCED” and Red Tractor logos and featured a quote from an individual farmer about their practices and aspirations alongside a roundel that stated “THE FUTURE OF FARMING”. It referred to “bringing quality, naturally delicious food to people’s plates”. We considered it was directly connected with the supply of goods and as such within the scope of the Code. However, we considered consumers would interpret the quote from the farmer about “looking after our Great British countryside” as reflective of their individual business practices, and the roundel text suggested they were newer and representative of what British agriculture hoped to focus on in the future. As such, we considered the basis of the claims were clear, and consumers were unlikely to interpret the ad as suggesting the practices referred to were currently reflective of British livestock farming’s overall environmental impact. It was therefore unlikely to mislead in relation to that.
Ads (f) and (g) featured images of a rural landscape and included claims that compared the carbon footprint of British beef and milk to the global average carbon footprint of producing beef and milk. While the ads highlighted an environmental benefit, it was made in the specific context of a comparison between British produce and the global average emissions of producing them (addressed at issue 2). The ad outlined that British beef and milk did cause environmental harm. We did not regard these ads as making a wider claim to environmental benefit.
On that point, we investigated ads (a), (b) and (c) under BCAP Code rules 3.1, 3.2 (Misleading advertising) and 9.2 and 9.5 (Environmental claims), but did not find them in breach. We investigated ads (d), (e), (f) and (g) under CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising) and 11.1 and 11.4 (Environmental claims), but did not find them in breach.
2. Upheld
The CAP Code stated that marketers must base environmental claims on the full life cycle of the advertised product, unless the marketing communication stated otherwise, and must make clear the limits of the life cycle. If a general claim cannot be justified, a more limited claim about specific aspects of a product might be justifiable. Marketers must ensure claims that are based on only part of the advertised product's life cycle do not mislead consumers about the product's total environmental impact.
We first considered AHDB’s contention that the ads (f) and (g) would be read as referring only to the cradle-to-retail stages of producing beef and milk. The top half of each ad featured a picture of the countryside, the bottom-half pictures of someone consuming farm produce – cooked beef and vegetables, and a glass of milk. Ad (f) stated, “British beef [...] has a carbon footprint that's half the global average” and ad (g) stated, “British milk [...] is produced to world class standards and has a carbon footprint a third lower than the global average”. Both ads included a footnote that stated, “[...] Full lifecycle emissions of CO2 eq per kg of beef/milk”. In our view the average consumer (being reasonably well-informed, observant and circumspect) was likely to understand the emissions claim as going beyond the retail stage to include consumption and disposal. We noted the results of a consumer survey produced very late in the investigation by AHDB. It did not directly address the extent of the claim in each ad, it also indicated that a significant majority of participants had not entirely ignored each ad’s footnote text, and the answers around how participants understood the scope of each ad’s comparison were far from conclusive with sizeable minorities viewing the claims as extending beyond production. We also reminded ourselves that it was for the ASA Council to reach its own judgment on how the average consumer was likely to understand the ads, and we considered consumers would view the claims as extending beyond the retail stage and accounting for post-retail actions they would engage in, such as cooking and wastage.
We then reviewed the substantiation AHDB provided. They referred to a meta-analysis and a 2020 report. The meta-analysis compared, from cradle-to-retail (from the extraction of resources to produce inputs for agricultural production to the retail store, including the disposal of product packaging), data from 570 studies across approximately 38,700 farms in 119 countries, focusing on 40 products that made up approximately 90% of global protein and calorie consumption between 2000 and 2016. The 2020 report drew on data from the meta-analysis to outline UK specific figures and because of that, while ads (f) and (g) referred to the 2020 report in footnote text, we assessed the meta-analysis when considering whether the claims in the ads were adequately substantiated.
We understood the meta-analysis, which compiled data between the cradle-to-retail stages of food production, had not considered emissions produced after the retail stage due to the high variability and lack of data. While we acknowledged the potential difficulties in producing post-retail emissions data, the claims in the ads suggested those emissions were included and we therefore expected the evidence provided to also include them. We therefore concluded that the evidence presented was insufficient to support the full life-cycle claims in the ads, which was how the average consumer was likely to interpret them. We reminded AHDB environmental claims should be based on the full life cycle unless the ad stated otherwise.
On that point, ads (f) and (g) breached CAP Code (edition 12) rules 3.1, 3.3 (Misleading advertising) and 3.7 (Substantiation) and 11.3 and 11.4 (Environmental claims).
3. Not upheld
Ads (a), (b) and (d) featured images of grassy fields and of cows grazing in green pastures. We considered consumers would understand the imagery was a generic reflection of how some cows were farmed in the UK, indicating they were farmed in a natural environment that was associated with rural areas. The ads did not suggest all cows were kept outdoors at all times, but that outdoor space was associated with a higher quality of farming and, as a result, food and milk.
According to Defra’s Cattle Farm Practices survey from April 2019, the latest available, 87% of cattle farms in the UK used a mix of housed and grazing systems: 9% had a year-round grazing system; and 4% housed their cattle all year round. Therefore, as most cattle were not housed all year, and most had some access to an outdoor environment, we considered the ads’ imagery, as it was likely to be understood by the average consumer, was unlikely to mislead.
On that point, we investigated ads (a) and (b) under BCAP Code rules 3.1, 3.2 (Misleading advertising) and 3.9 (Substantiation), but did not find them in breach.
We investigated ad (d) under CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising) and 3.7 (Substantiation), but did not find it in breach.
Action
Ads (f) and (g) must not appear again in the form complained of. We told the Agriculture and Horticulture Development Board t/a AHDB to ensure that claims about product life-cycle emissions were appropriately explained and supported to avoid misleading.
