Ads for Plenish almond drink, seen in September 2018:
a. A poster ad stated "IT'S TIME TO GO NUTS. A recent study by the University of Oxford showed that the single biggest thing that you can do to reduce your impact on the planet is to switch to a plant-based diet. Search 'Plenish' to get started. PLENISH...START SOMEWHERE". The ad featured an image of a package of Plenish almond drink with a white liquid and almonds bursting out of it.
b. A poster ad stated "IF YOU WANT TO CHANGE THE WORLD CHANGE YOUR MILK. A recent study by the University of Oxford showed that the single biggest thing that you can do to reduce your impact on the planet is to switch to a plant-based diet. Search 'Plenish' to get started. PLENISH...START SOMEWHERE". The ad featured the same image as ad (a).
Two complainants, who understood that almond production could have a negative impact on water levels, challenged whether the ads misleadingly exaggerated the environmental benefits of the product.
Plenish Cleanse Ltd said that they had worked closely with a scientist at Oxford University who had completed one of the largest and most comprehensive studies of the full lifecycle of food products, including meat and dairy, and their environmental impact. The results had been widely published. They had worked with the same team to design and analyse the supply chain of their almond drink.
Plenish Cleanse said dietary change as they were promoting in their ads could deliver environmental benefits on a scale that was not achievable by producers like them exclusively. They were aware that it was a lot to ask people to eliminate all animal products from their diet immediately, and instead suggested a small change like swapping dairy for Plenish almond drink.
Plenish Cleanse said that the almonds in their product were sourced from low-impact farms in Spain, in regions such as Mallorca and Malaga which were not encumbered by drought. They provided the lifecycle analysis, which covered the product from farm stage through to transporting and retail, as well as comparative data for cow’s milk production both in the UK and abroad.
Ad (a) stated “A recent study by the University of Oxford showed that the single biggest thing that you can do to reduce your impact on the planet is to switch to a plant-based diet”. The image featured almonds and a liquid that looked similar to cow’s milk and further text stated “Search 'Plenish' to get started” and “PLENISH...START SOMEWHERE”. Taking the combination of these elements into account, the ASA considered that consumers would understand that switching from cow’s milk to Plenish almond drink was one way in which they could transition to a more plant-based diet. They would therefore understand that Plenish almond drink had a lower overall environmental impact than cow’s milk available to UK consumers. In the absence of any information to the contrary, we considered that consumers would understand that claim was based on the full lifecycle of the product.
Ad (b) was headed "IF YOU WANT TO CHANGE THE WORLD CHANGE YOUR MILK”. In the context of the rest of the text, which was the same as in ad (a), we considered that the overall impression of the ad was the same as ad (a).
The complainants had expressed concerns that almond production could have a negative impact on water levels, particularly in certain areas of the world that were already affected by drought. We noted that the almonds used in Plenish almond drink were not sourced from those areas.
We assessed the data provided. The comparative data had been taken from a comprehensive study on the environmental impact of farming around the world. It covered greenhouse gas (GHG) emissions from farming, processing, transport, packaging and retail. In addition, it included data on acidification (air pollution), eutrophication (water pollution), land use and water use. The impact per litre of each of these aspects was lower for Plenish almond drink when compared with global data on cow’s milk. Looking at data specifically for the UK, the impact of Plenish almond drink was lower in terms of GHG emissions, acidification, eutrophication and water use. Impact in terms of land use was higher, and we understood from Plenish that this was due to the non-intensive farming methods used.
Overall, we considered that Plenish Cleanse had demonstrated that their almond drink had a lower impact on the environment than cow’s milk, when taking into account the full lifecycle of the product, which was the impression that consumers were likely to take from the ads. We concluded that the ads were not misleading.
Ads (a) and (b) were investigated under CAP Code (Edition 12) rules 3.1 3.1 Marketing communications must not materially mislead or be likely to do so. (Misleading advertising), 3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation. (Substantiation), 3.11 3.11 Marketing communications must not mislead consumers by exaggerating the capability or performance of a product. (Exaggeration), 3.33 3.33 Marketing communications that include a comparison with an identifiable competitor must not mislead, or be likely to mislead, the consumer about either the advertised product or the competing product. (Comparisons), 11.1 11.1 The basis of environmental claims must be clear. Unqualified claims could mislead if they omit significant information. 11.3 11.3 Absolute claims must be supported by a high level of substantiation. Comparative claims such as "greener" or "friendlier" can be justified, for example, if the advertised product provides a total environmental benefit over that of the marketer's previous product or competitor products and the basis of the comparison is clear. and 11.4 11.4 Marketers must base environmental claims on the full life cycle of the advertised product, unless the marketing communication states 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. (Environmental claims), but were not found in breach.
No further action required.