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 that 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, and the Ruling (and references to rules within it) should therefore be read in line with this wording, available here – CAP Code and BCAP Code

Ad description

A TV ad for Assured Food Standards' Red Tractor Scheme, seen on 1 May 2023. A voice-over stated in rhyme, “Farmed with care, that's the Red Tractor way. A label to trust, found on food every day. This promise is kept by the checks put in place, to care for our animals with the right food and space. Our cows have a health plan, and a personal vet, from field to store all our standards are met. When the Red Tractor's there, your food's farmed with care”. 
 
It featured an animated sequence of a person pushing a shopping trolley: firstly, through the aisles of a food shop, where a poster with the Red Tractor logo, which featured the text “CERTIFIED STANDARDS” and further text “FARMED WITH CARE”, was displayed; then outside, passing a flock of sheep and a tractor, through the barn of a dairy herd; and finally back into the food shop. 
 
The ad concluded with an image of the Red Tractor logo, again showing the text “CERTIFIED STANDARDS”, surrounded by sausages, broccoli, flour, apples, cheese and chicken. Bold text stated, “FARMED WITH CARE”. 

Issue

River Action challenged whether the ad exaggerated the benefits of Red Tractor endorsement because they understood (based on reports from the Environment Agency) that some environmental standards relating to pollution on Red Tractor Assured farms were not met. 

Response

Assured Food Standards t/a Red Tractor (RT) explained that RT Assured quality standards (RT standards) applied primarily to farming standards, animal welfare and food traceability. RT certification was a commitment to ensure that rigorous standards were met across a range of different issues within those areas for the purpose of food safety and Assured status was dependent on every operator meeting all RT standards. Certification was split into several categories (for example, dairy, beef & lamb, chicken, pigs, crops & sugar beet, and horticulture) with similarities and nuanced differences between them. Membership was by category, with some sites certified in more than one category, such that in 2023, of approximately 100,000 farms in the UK, there were 53,160 assured memberships across 40,188 assured sites. The vast majority of dairy farms (97.5% in 2023) were RT assured. 
 
RT Assurance was a ‘food chain assurance scheme’ – it set standards, ensured compliance and certified every stage of the food chain (not just on-farm). Furthermore, it undertook traceability audits to ensure the integrity of the use of the RT claim and logo on every product or menu item. The standards were based on science, evidence, legislation and consumer demand. 

They explained that RT supplemented and built on government action through four routes: 

  1. Additional standards which went above and beyond legislation. 
  2. Independent inspection of every farm on a 12- or 18-month cycle (dependent on species). 
  3. Robust sanctions which, at their toughest, could remove a farmer’s business from the Red Tractor scheme.  
  4. Comprehensive standards that covered all the principal elements of food production. 

Turning to the likely consumer interpretation of the ad, RT did not consider the average consumer would understand that any of the claims made in the ad were references to the environment. The ad’s imagery, together with the script, would be understood by the average consumer as explaining the core aspects of the RT scheme, farming standards, food traceability and animal welfare. The ad’s claim that “from field to store all our standards are met” reflected that no other assurance scheme or government organisation performed as many checks across as many farms or food businesses as they did. 
 
They referred to market research completed in 2019. There was only one mention (out of 331 participants) of the environment, in response to an open-ended question about RT’s “Farmed with care” logo. The research also examined what motivated consumers’ food purchasing decisions. Its outcome was that UK shoppers were primarily concerned with appearance, price and pack size. Environmental credentials were only ranked as a top three consideration for between 8% and 10% of shoppers within the sample depending on the category. Additional research by an agency on behalf of RT outlined that of 300 participants who were asked about what they associated with RT, four mentioned “sustainable”, two mentioned “sustainability” and none mentioned the environment more generally. They believed the only way the average consumer would interpret the claims in the ad as implied environmental claims was if they spent significant time on the RT website and proactively looked for information about RT standards, including how they applied to the environment. 
 
RT further believed, in the context of the ad, it was clear that the claim “all our standards are met” related to RT’s own standards, some examples of which were highlighted in the ad. There was no reference to legal standards and no reference to environmental law. Therefore, the claims “certified standards” and “all our standards are met” were understood by the average consumer to refer to RT’s own standards and not legal or regulatory requirements in relation to the environment (that are neither set nor enforced by RT). The ad was shown on mainstream broadcast channels in the UK and targeted UK consumers generally. 
 
Although environmental protection was not the primary focus of RT standards, a small number of them did serve to minimise and mitigate the risks of contamination and pollution. They included requirements that, for assured farms in all categories, potential pollutants, including organic manure and sileage, must be stored in a manner that minimised the risk of contamination and pollution to crops, feedstuffs, animals, soils, groundwater and watercourses. For example, fertiliser must be kept on a hard surface and manures must be stored more than 10m away from inland freshwaters or coastal waters, or more than 50m away from a spring, well or borehole, where there was significant risk of runoff entering watercourses. There were also requirements to ensure that effluent runoff did not enter a watercourse, either directly or through land drains, roads, tracks or other pathways. 
 
However, because RT was not an environmental certification mark specifically, those standards did not seek to replicate environmental law or even cover all aspects of pollution risks by farms. RT explained that while environmental legislation (which was under the jurisdiction of the Environment Agency (EA)) applied to everyone and imposed mandatory obligations, RT was a voluntary, third-party quality assurance scheme. Their quality assurance was a more holistic and involved approach, based on setting standards across the supply chain and designed to ensure better outcomes in terms of food safety and traceability. Legislation regarding pollution focused on outcomes (for example, whether an incident of surface water pollution had occurred). RT standards had some overlap with environmental legislation, and the RT standards were in keeping with the ethos that members ‘farm with care’, in line with RT’s core purposes of food safety, food traceability, and animal welfare. 
 
RT’s standards were intended to be in addition to the law, with RT standards being monitored more regularly than compliance with environmental law and, in some areas, RT Assured farms had to comply to a higher standard. For example, although there were legal requirements for the positioning of organic manures on chicken farms and their distance from a water source, there were exemptions for storage that pre-dated 1991. The same requirement applied to all RT Assured farms, irrespective of age. In addition, where manure was stored temporarily, RT required removal every 12 months regardless of location, whereas legal requirements applied only to parts of England that had been designated as Nitrate Vulnerable Zones. 
 
The certification bodies associated with RT standards were all UKAS accredited (the UK’s National Accreditation Body) and operated under the International Organisation for Standardisation ISO 17065 (for bodies certifying products, processes and services), which required competence, impartiality and consistency. In an average year there were approximately 37,690 farm assessments (inspections) undertaken on RT assured farms by the independent assessors (and not RT). The average number of audit points per sector (i.e., per membership category) was over 500 across 180 standards. RT explained that their data showed that farms were typically 98% compliant with RT standards at the time of assessment. Of the 2% where non-conformances were found, many of those were for minor or administrative issues which were required to be remedied within 28 days. If the non-conformance was more serious, the assessor overseeing the inspection was likely to set a tighter deadline. In order to resolve the non-conformance, satisfactory evidence demonstrating that the breach had been sufficiently addressed had to be provided to the certification body. The certification body must be satisfied that the member then complied with the standard noted for non-conformance in order to certify that member (i.e., 100% compliance with RT’s standards. For very serious breaches where no remedy was possible, it was likely that membership would be suspended or withdrawn with immediate effect by the certification body. 
 
Suspension was usually a short-term measure. Between 2021 (when the most recent standards were introduced) and May 2023, RT confirmed that 5,747 RT Assured farms had had their membership suspended while actions were taken to comply with RT standards, and 474 members had their certification and membership withdrawn. In relation to environmental non-conformances, 327 had been suspended and 123 withdrawn due to management of inputs or resources that were a pollution risk over the same period. 
 
Where a RT inspection uncovered a serious pollution incident, this would be reported to the EA. Two members were reported to the EA between November 2021 and May 2023. In the event of the reverse scenario, whereby a problem was uncovered through an EA inspection, that would not be reported by the Agency to RT directly. However, it was a requirement of RT membership that members self-declared to the certification body any prosecution that was brought or likely to be brought against a farm. This included the reporting of any action taken by the EA on the occasion of a pollution incident. 
 
Other than the physical inspections carried out by the certification body on behalf of RT, RT also monitored the UK media daily for reporting on its member farms and their associates. In any circumstance, where there was a question of compliance with their standards, membership from the RT scheme would be suspended pending review. Foods produced thereafter could not be labelled and sold to consumers as “Red Tractor assured” during this process. Therefore, the commercial consequences of losing membership were typically very significant. To ensure transparency, the number of all suspensions and withdrawals was published quarterly on the RT website. 
 
Re-admittance to the scheme following suspension or withdrawal relied on various factors. For example, there may be additional conditions of certification applied to a membership, which could range from additional spot checks or inspections, training needs or third-party involvement. RT gave examples of some that had been applied, which included among other things: a full audit with zero non-conformances, installation of CCTV with footage recorded 24 hours a day, unannounced spot checks, additional vet visits, decommissioning of unsuitable buildings, and herd reduction. A member could only be readmitted when the certification body was satisfied that RT’s membership rules plus any additional conditions had been met. In reality, some withdrawn farms could not achieve readmittance and it was that combination of standards, independent inspection, and robust sanctions that underpinned RT’s ethos of “farmed with care”. 
 
Regardless, RT acknowledged that, as at May 2023, UK agriculture had work to do in addressing water pollution, and that reducing agricultural pollution was a difficult problem which required action from across the industry, including RT, central government and the regulator (the EA). They explained that the reports referenced by River Action to support their complaint represented data collected by the EA between 2014 and 2019. River Action referred to a statistic cited by the EA, which stated that “62% of the most critical incidents (category 1 and 2), occur on Red Tractor farms”. RT explained that to contextualise this statistic, this represented 250 incidents between 2014 and 2019 on a reported 59,013 RT farms used for the construction of the EA’s report. That demonstrated a category 1 or 2 incident occurring on 0.4% of the total number of RT farms over a period of 5 years. Therefore, whilst 62% of incidents sounded high, RT believed, in reality, it was a tiny percentage of farms (0.4%) over a significant time-period (5 years). 
 
Having relied on data gathered between 2014 and 2019, the EA’s reports did not recognise improvements built into the system since November 2021, when RT introduced its latest standards. In 2021, RT raised their standards relating to the appropriate containment of potential pollutants, up-to-date calculations for slurry storage requirements, and the introduction for some memberships of requirements for pesticides qualifications and insecticide schemes for environmental protection. They noted that the incidents recorded by the EA in its report fell from 77 in 2018 to 42 in 2019, which was a 45% year-on-year decline and a 75+% reduction on 2000 levels. They explained that around a half of the incidents in 2019 occurred on dairy farms, but that number also fell for the fourth successive year. 
 
RT explained that the EA inspected 4,000 farms per year out of over 100,000 farms in England. That was less than 4% of farms per year. Prior to 2021, inspection numbers were fewer than 500 per year (0.5% of farms). By comparison, RT ensured routine, independent inspection of 100% of its members on a 12- or 18-month cycle. In addition, they explained that EA inspection was biased towards farms that, from existing or previous knowledge, were more likely to fail. The EA had recently shared more, limited findings with RT, based on inspections carried out between 2014 and 2024. RT had not seen the full dataset. However, the same concern applied; by intentionally targeting high-risk sectors and catchments, the data on which the findings were based, by design, was not a representative sample of all farms or importantly, of all RT farms. Furthermore, comparisons needed to take into account the declining size of the farming population since 2014. 
 
In addition, RT highlighted a letter written by EA’s Head of Agriculture to The Times, which had featured an article about the EA findings. The letter, which was unpublished, explained that the findings had been misrepresented and the EA “actually found that the number of pollution incidents on RTA farms would appear to be lower than might be expected by chance based on the representation of farm types in the scheme”. They believed this acknowledged that RT did have a positive impact on the environment. The statement also reflected that RT were continuing to work with the EA to explore improvement and verification of RT’s environmental standards (further evidencing RT’s proactiveness to improving its standards). 
 
RT acknowledged that, in principle, it was possible that there could be instances where individual members met all RT’s standards but nonetheless, as a result of some action not covered by RT’s standards, there was still a breach of environmental law including a potential pollution incident. It was also possible that due to the somewhat unpredictable nature of farming, a breach of environmental law could occur after a RT inspection had demonstrated full compliance but before the next inspection was due. For example, an unexpected event such as extreme weather could cause a slurry storage facility which was, at the time of inspection, fully compliant with RT standards, to leak into a river or water source. So, there could be both a fully substantiated claim of “all our [RT’s] standards are met” and the finding of a pollution incident by the EA. But RT said that their data suggested that would be an exceptional and isolated example. 
 
RT also noted the EA’s data related to compliance with environmental law and not necessarily instances of actual pollution. Non-compliance with environmental law included a wide range of possible issues: everything from very serious environmental damage to breaches that were process or paperwork based. From an average consumer’s perspective, those process or administrative-related breaches would not necessarily constitute a lack of environmental care. 
 
RT highlighted that the Food Standards Agency (FSA) extended ‘earned recognition’ to Red Tractor farmers, reducing their likelihood of inspection from the FSA enforcement authority. The United Nations Industrial Development Organization (UNIDO) used RT as an exemplar of third-party food assurance. Codex Alimentarius, a collection of internationally recognised standards, codes of practice, guidelines and recommendations published by the Food and Agriculture Organisation of the United Nations, ratified and recommended the use of third-party voluntary programmes, and used RT and its relationship with the FSA as the exemplar. RT said the combination of UK legislation, government enforcement and their additional standards underpinned the fact that Britain had some of the highest food and farming standards in the world. 
 
Clearcast believed the substantiation provided was enough to support the benefits of RT endorsement. 

Assessment

Upheld 

The ASA’s starting point was to assess how the notional average consumer, who was reasonably well-informed and reasonably observant and circumspect, was likely to view the ad. 
 
The ad featured a combination of specific and non-specific statements and visual imagery. Specific claims related to the welfare of farmed animals – the provision of good food, living conditions and healthcare through RT assurance. Other claims were broader in scope – “Farmed with care, that's the Red Tractor way […]”, “A label to trust, found on food every day”, “This promise is kept by the checks put in place”, “When the Red Tractor's there, your food's farmed with care”. The ad also stated “[…] from field to store all our standards are met”, highlighting the assurance of Red Tractor labelling across all aspects of food production and farming. 
 
The statement “our standards” was directly qualified by the word “certified”. In addition, it was clear that the standards included a health plan and a personal vet for cows. However, the ad did not elaborate further on the standards or what they represented in relation to farming provisions from “field to store”, and consumers were not directed, for example, to the RT website for further information. We considered that the claims above, together with the different food types depicted and the pastoral imagery, which included green fields and shrubland and a dairy farm as part of the animated sequence, contributed to an impression that implied RT Assured foods were subject to certified standards, which sought to achieve high levels of care, across the full journey over which food was produced. Many consumers would associate those standards with the care given to animals as part of the dairy and meat production chain, as well as standards associated with arable farmed products such as fruit, vegetables and grain. We further considered that at least a significant minority of those consumers (sharing the characteristics of the notional average consumer) would also expect that, in giving assurances about high standards of farming and food production, such standards would encompass measures to manage and mitigate environmental risk that arose through farming practices. Those consumers would consider there was an inextricable relationship between high quality food production and the environment that food was grown or reared in; for example, through responsible land, river and ground water quality management and soil health. 
 
We noted the advertiser’s 2019 consumer research about associations consumers had with Red Tractor and farming. Only one participant had associated the RT logo with ‘environmentally friendly standards’ and one with ‘sustainability’. However, the category that the highest number of participants (24) identified with was “Net British / National”, nine reacted ‘Don’t know’, 11 said ‘Other’ and four said ‘Nothing’. In addition, a survey of 178 consumers who were asked for their understanding of the ad, having seen content related to food, showed that four responded ‘Sustainable’ and two, ‘sustainability’. The highest number responded ‘farming’ and ‘Meat’ (28 and 23 respectively); 14 said ‘Nothing’, three said ‘animal welfare’ and one said ‘good quality’. It was not possible, therefore to deduce robust conclusions from the findings. We nonetheless reminded ourselves that the ASA’s expertise lay in the assessment of ads, and took the view that many consumers had heightened expectations in relation to the environment. 
 
We also considered that consumers sharing the characteristics of the notional average consumer would expect, absent any explanation, that such standards incorporated compliance with or reflected at least basic legal requirements concerning food safety, animal welfare and environmental protection. Also, that measures were in place to help produce a high standard and quality of food (in line with the objectives of the RT scheme, which included appropriate environmental measures, as the RT website explained, within a section for members), that the structure of the standards scheme was sufficiently robust to deliver them, and that the standards applied to all stages of the journey of food throughout its production. Where such standards (including the basic legal requirements) were not met, those consumers would expect that appropriate and robust corrective measures (which might ultimately include removal from the scheme) were in place to ensure that the standards of the scheme were upheld by its members. 
 
Whilst the claim “all our standards are met” might be viewed as an absolute rather than a comparative claim, in our view consumers would not understand that a certification scheme like RT’s was an absolute guarantee of those standards being met in all circumstances. In that context, consumers would not interpret the claim “from field to store all our standards are met” literally, as a guarantee that there was 100% compliance with all RT’s standards at all times, and that there were no instances of non-compliance with environmental standards in any RT farms. We noted the RT Assured scheme included 53,160 memberships across 40,188 sites in 2023. RT had explained that the standards they applied were primarily focused on farming practices relevant to food and safety but confirmed that they also included other areas of farming activity such as environmental protection. There were, for instance, requirements for the positioning and storage of potential pollutants to prevent contamination, the removal of waste matter and the correct maintenance and handling of plant protection products. 
 
RT committed to carry out an audit of all members across every 12- or 18-month cycle. From November 2021, leading up to the ad’s appearance in May 2023, the average level of compliance across all standards was 98% at the time of assessment. There were 450 non-conformances with RT’s environmental standards found for the period 1 November 2021 to 31 May 2023 (of which 327 farms were suspended from the scheme pending remedial action and 123 farms had their membership withdrawn). From an annual inspection rate of 37,690 RT farms, that equated to an approximate non-conformance rate of 1.2%. Where a non-conformance was uncovered, a farm had a maximum of 28 days to address the inspector’s concern, or face further sanction. In the case of a more serious incident, the time scale could be shorter. Therefore, where non-conformances with RT’s standards were found, a farm had the choice to either work with the certification body to rectify the non-conformances (so as to be 100% compliant with RT standards) within a short time frame (typically 28 days) in order to remain assured or leave the scheme (with the significant commercial consequences that this brought). 
 
The enforcement of environmental legislation was the responsibility of the regulator. In the case of water standards and, therefore, pollution incidents, that was the EA. River Action had referred to EA reports titled “Assessment of the environmental performance of Red Tractor Assured farms” and “North Devon Priority Focus Area”. The first, “Assessment of the environmental performance of Red Tractor Assured farms”, was dated February 2020 and was based on EA and RT data collected between 2014 and 2019. It covered the results of 3,000 EA inspections and 239,000 RT assessments (RTA), across all farming sectors. Of 4,064 pollution incidents, the results stated, “RTA farms were responsible for a significant number of pollution incidents (62% of category 1 and 2 incidents, 56% of category 3 incidents)”. However, looking specifically at dairy, as Red Tractor assure the majority of commercial dairy farms, incidents caused by RT Assured farms “appeared to be slightly lower than might be expected ... Slurry caused the most pollution incidents, accounting for 30% of total”. 
 
The report, which was commissioned in order to assess whether the EA’s earned recognition status could be awarded to RT Assured farms (with a view to offering a reduced EA inspection rate to those farms), stated in conclusion “The evidence gathered through this project demonstrates that Red Tractor membership is not currently an indicator of good environmental performance, and therefore we do not recommend extending Earned Recognition to RTA farms”. It further stated, “However, the evidence shows we should acknowledge the relatively good environmental performance of Red Tractor horticulture sector scheme members”. In response to the report’s findings, RT committed to take several issues to their formal governance Technical Advisory Committee for further discussion, including “Measures to reduce pollution incidents”, “Slurry and silage storage” and “Contingency planning for environmental incidents (e.g., agrochemical/slurry spills, floods)”. 
 
The “North Devon Priority Focus Area” (NFPDA) report, published by the EA in 2022, was based on evidence collected from targeted farms between 2016 and 2020. Inspections were carried out by one investigator on farms with a minimum of 100 cattle in the North Devon region, where incidents had previously been reported or where practices were reported as being at risk to watercourses. Visits were mainly unannounced and conducted between October and March when animals were more likely to be housed; 101 farms were visited. The results showed that 87% were non-compliant with the rules being investigated by the EA, despite almost all (as was to be expected given RT’s high share of membership among dairy farms) being RT members. The recommendations in the report, of which there were 18, identified several ways in which compliance with environmental legislation in the region could be improved. One of the recommendations was, “Food chain inspecting schemes such as Red Tractor ensuring that their inspectors are properly trained on environmental protection and infrastructure requirements especially. As they have a lot of coverage, they can be extremely influential”. 
 
We acknowledged RT’s contention that the reports were based on data collected between 2014 and 2020 (and in the case of the North Devon report, from a small area). In 2017, RT had introduced changes to slurry storage and handling standards on dairy farms, which took time to implement and assess against. New legislation, such as The Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018 was introduced, and the use of a ‘slurry wizard’ tool for farmers to assess legally required slurry storage capacity was made mandatory in 2019. This was noted in the EA report titled “Assessment of the environmental performance of RT Assured farms”, which recognised that, due to the timing of the introduction of the slurry wizard tool, the report’s analysis could not take any impact of the newly introduced standard into account. The data, due to when it was produced, was therefore not necessarily representative of RT farms at the time the ad was broadcast. 
 
The EA also held data on RT Assured farms (and Unassured farms) through inspections from 2014 to 2024, with the majority of the inspections having taken place between 2021 and March 2024. The number of EA inspections had risen significantly towards the end of the period (from 500 to 4,000 per year). A summary of the data as provided to the ASA and RT, showed that, from a total of 10,543 inspections across all farms (of which 5,695 were RT assured), 48% were not fully compliant with the regulations on “farming rules for water”, “rules for storing silage, slurry, and agricultural fuel oi”’, and “rules regarding nitrate vulnerable zones”, with around half of RT farms being not fully compliant. We understood that the EA inspections targeted farms for inspection based on a number of factors, including high risk sectors and protected areas, so the data could not be used to extrapolate a representative picture of compliance across all RT farms when the ad was broadcast. Nevertheless, it did indicate that there was an issue with RT farms’ compliance with statutory environmental regulations at the time the ad appeared. We further understood that the EA did not share compliance results of individual farms with RT. This was due to personal and criminal data sharing rules, which prohibited the sharing of compliance data until it had gone through court, unless the data was part of a permit under Environmental Permitting Regulations, in which case it was available on the Public Register. However, EA explained they had shared the overall compliance rates with RT a number of times over the years, including by sector and what interventions were issued. 
 
It was for RT to substantiate the claims in the ad. Although they did provide the number of withdrawals and suspensions relating to non-conformance with environmental standards (which they said required an extraordinary exercise to provide), and the number of members that RT reported to the EA, they were not able to provide data relating to pollution incidents themselves (as RT’s standards were not outcome based). Although the EA did not disclose the results of individual assessments, when the EA discovered a breach of environmental legislation at a RT farm that resulted in a prosecution, or was likely to, the farm was required to self-report to the independent certification body acting on behalf of RT. However, data to demonstrate self-reporting was not shared by the certification body with RT and they did not hold records of actions taken following self-reporting as a result. In addition, RT was not able to provide information about compliance performance in the period preceding May 2023 among North Devon cattle farms, where problems had been noted previously. We asked RT about evidence of adherence to environmental standards (including legislative) in another area with well documented pollution issues (the River Wye catchment area, in respect of poultry farms), but RT were not able to provide statistical information for these EA catchment areas. 
 
Some elements of environmental legislation, such as paperwork infringements, or an isolated spillage that could be easily cleaned, which could result in a failure of an environmental legislation inspection as reported by the EA, might well not be relevant for the purposes of assessing RT’s own standards. It was to be expected that there would always be a level of non-compliance against any assurance or control measure. However, whilst what RT told us during the investigation suggested an extensive process to secure compliance with RT’s own standards relating to pollution and soil management, the evidence to demonstrate compliance with basic legislative standards and a good environmental outcome was in our view insufficient to substantiate, as at May 2023, the wider claim which “farmed with care … all our standards are met” conveyed (to at least a substantial minority of those sharing the characteristics of the average consumer). The ad was, therefore, likely to exaggerate the benefits of Red Tractor endorsement. 
 
The ad breached BCAP Code rules 3.1, 3.2 (Misleading advertising), 3.9 (Substantiation), and 3.12 (Exaggeration). 

Action

The ad must not appear again in its current form. We told Assured Food Standards t/a Red Tractor, when claiming “farmed with care” in conjunction with “all our standards are met” in advertising, to make clear exactly what standards they were referring to, and the degree to which they claimed that they were being met.

BCAP Code

3.1     3.2     3.9     3.12    


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