Background
Summary of Council decision
Three issues were investigated, all of which were Upheld.
Ad description
A post on Untamed Cat Food’s own Instagram account, seen on 28 September 2025, featured a presenter walking down a supermarket aisle. Text stated, “THE WORST PET FOOD YOU WILL FIND IN THE SUPERMARKET [banned sign emoji]. The presenter said, “In ten seconds I’m going to tell you the worst cat food you will find in the supermarket.” She held up three different cat food products with varying degrees of blurring to the text and images. Referring to the first product she said, “If you see ‘rich in’ that means there’s a minimum of 14% meat in the product, that’s certainly not ‘rich.” Referring to the second product she said, “If you see ‘with’ that means there’s a minimum of 4% meat in the product.” Referring to the third product she said, “And if you see the word ‘flavour’ that means there doesn’t have to be any of this ingredient in the product whatsoever.”
The presenter continued to walk down the aisle. She said, “The common problem with all these brands is they don’t even come close to the 100% whole meat nutrition that your cat needs. Your cat is an obligate carnivore meaning their bodies require nutrients that are only found in animal proteins.” The presenter picked a tin of Untamed cat food from the shelf. She said, “This is the best option out there in my opinion. It’s called Untamed. You get 100% human grade meat, gently steam cooked to preserve nutrients, with none of the fillers or cereals those other brands use to make up for the lack of meat content […] Whole meat recipes like these can help improve your cat’s energy, coat condition and overall health and longevity.” The presenter went on to refer to “premium quality food” and “(helping) your cat thrive”.
The accompanying caption stated, “Shocking but true: Most cat food contains as little as 4% named meat. Cats are carnivores, they need meat to thrive! That’s why Untamed is: [meat emoji] Made with 100% fresh, real meat & wild fish [chef emoji] Hand-prepared in human food facilities [weightlifting emoji] Up to 2X more protein than leading brands”.
Issue
The complainant challenged whether the following claims were misleading:
- “the worst pet food you will find in the supermarket”;
- the claims relating to the percentages of meat in other products; and
- “the common problem with all these brands is they don’t even come close to the 100% whole meat nutrition that your cat needs”.
Response
Untamed Cat Food Ltd (Untamed) said the ad had run for less than four weeks, was no longer being shown and would not be repeated.
1. Untamed said the phrase “the worst pet food you will find in the supermarket” was an introductory line and was not linked to any particular product. The ad went on to explain why the cat food it referred to was “the worst”; Untamed believed consumers would therefore understand the claim as referring to the products with low meat content described later in the ad.
They believed the claim did not relate to identifiable competitors because the packaging shown as examples was blurred to prevent identification of specific products or brands. They intended to illustrate industry-wide practices rather than to target individual products. Notwithstanding that, they believed it to be an objective comparison because it was based on the meat content of the applicable cat foods, and the “worst” were consequently those that satisfied only the minimum standards in that respect. They contrasted that with their own product’s higher meat content and lower additive, preservative and filler content. They said they would not use the phrase in their future advertising however.
2. Untamed referenced the European Pet Food Industry Association (FEDIAF) Code of Good Labelling Practice for Pet Food, which set ingredient thresholds for specific claims.
Untamed confirmed that “rich in” required at least 14% of the named meat or fish ingredient to be in the product. They believed the claim in the ad would be understood in the context of the presenter simultaneously holding up a product where the packaging clearly stated “Rich in tuna”. It would therefore be seen as referring to tuna rather than to the total or combined meat or fish content, as the complainant had challenged.
Untamed confirmed that “with” required a product to contain at least 4% of a specific named ingredient. As before, they believed consumers would understand the “meat” reference as referring to the individually named ingredient shown on the pack, rather than to the total or combined meat or fish content, as the complainant had challenged.
The complainant had also noted the claim “If you see the word ‘flavour’ that means there doesn’t have to be any of this ingredient in the product whatsoever” appeared alongside a product that stated “flavoured with”, which required a certain percentage of the named ingredient. Untamed confirmed in contrast that “flavour” did not require the product to contain the named ingredient, provided the flavouring substance was indicated. They said they had therefore shown the “flavoured with” product in error.
3. Untamed said scientific literature recognised that cats, as obligate carnivores – animals whose diet in the wild required nutrients only found in animal tissue – needed certain nutrients. They acknowledged that the diet of cats did not need to be entirely comprised of meat to be nutritionally adequate, and said the ad intended to highlight the difference between products meeting only the minimum FEDIAF thresholds for “with” or “rich in” claims and higher meat recipes such as their own. They believed consumers would be surprised by how little named meat or fish could be present in food described as “rich in” or “with”, and said those minimum-threshold products could provide less of a cat’s daily nutritional needs, compared to high meat diets, and would fall short of consumer expectations for products marketed as “rich in”.
Untamed said “these brands” referred to the type of products shown in the ad, namely those only meeting the minimum FEDIAF criteria, such as 14% chicken or 4% tuna. In response to the complainant’s point that necessary moisture content would lower the overall meat percentage in all wet foods, they said their recipes contained around 60% named meat or fish plus approximately 37–38% broth, while the competitor products shown had similar moisture levels but only 4–14% named meat or fish; moisture did not, therefore explain the gap.
Untamed believed the context of the ad made clear that “100%” qualified the nature and standard of the meat and fish ingredients used and was not a reference to the composition of the finished product. The “100% human grade meat” and “100% fresh, real meat” claims were about ingredient quality and not that the finished wet-food product was 100% whole meat. They also believed the average consumer would understand the difference between “made with” and “made entirely from” and would understand that wet cat food contained some moisture or broth. Untamed did not contend that broth or moisture should be treated as “whole meat”. The descriptions “fresh” “real” and “wild” reinforced the fact that the caption was describing the quality and nature of the ingredients used rather than that the finished recipe was 100% meat by composition. They gave examples commonly used in the food industry such as chicken nuggets made with “100% chicken breast meat” and fish fingers “made from 100% fish fillet”. Nevertheless, they said they would not use the spoken claim again.
Assessment
1. Upheld
The CAP Code required that comparisons with identifiable competitors must objectively compare one or more material, relevant, verifiable and representative feature. The ad stated in the voice-over at the start, “In ten seconds I’m going to tell you the worst pet food you will find in the supermarket” and the on-screen text stated, “THE WORST PET FOOD YOU WILL FIND IN THE SUPERMARKET”. The presenter went on to hold up three individual cat food products. The ad also showed supermarket shelves of cat food. Although the packaging was blurred, the blurring did not fully disguise the products’ colour, text, design and illustrations. We therefore considered consumers were likely to be able to identify the specific brands and products and therefore the ad made comparisons with identifiable competitors.
The ASA considered that consumers were likely to interpret the claim “the worst pet food you will find in the supermarket” as a comparative claim. We considered that comparison could reasonably be understood in one of two ways; either as referring to the specific products referenced, or more broadly to cat foods commonly available in supermarkets as a category. We considered that, in either case, consumers would expect the claim to be supported by objective data. Although Untamed explained that they had based the claim on meat content, we considered the ad overall did not suggest that the claim was limited to that feature. Instead, we considered consumers were likely to understand the claim “the worst pet food”, which appeared at the start of the ad, as a judgement not only about the specific products held up but about the overall quality of cat food commonly available in supermarkets.
We considered that, to support a claim that certain cat foods were “the worst”, Untamed would need to demonstrate that cat foods commonly available in supermarkets more generally had been assessed against appropriate and relevant criteria and found to perform worst against those criteria. However, we had not seen evidence that those products were objectively the “worst” cat foods available in supermarkets, or that having the minimum threshold of meat alone justified an overall judgement about quality relative to the wider market.
We welcomed Untamed’s assurance that they would not use the phrase in future advertising. However, we considered for the reasons above, the claim was misleading and breached the Code.
On that point, the ad breached CAP Code rules 3.1 (Misleading advertising), 3.7 (Substantiation), 3.32 (Comparisons with identifiable competitors) and 3.34 (Comparisons with identifiable competitors).
2. Upheld
We understood the FEDIAF Code stipulated the minimum percentages of a named ingredient that a product was required to contain in order for it to state on the packaging ‘rich in’ or ‘with’. A product therefore that contained the minimum percentage of combined meats or fish, but not of the specific named meat or fish variety on the packaging, could not use that labelling. We considered consumers were likely to interpret the claims about the percentages of meat and “flavour” as relating to the ingredients of the products being held up by the presenter.
We acknowledged that the specific named meats were visible on the packaging, and that the caption referred to “as little as 4% named meat”, however, the voice-over and the on-screen text, which were more prominent, referred simply to “meat”. We therefore considered the claims “there’s a minimum of 14% meat in the product” and “there’s a minimum of 4% meat in the product” were likely to be understood as referring to the overall meat or fish-based content of a product, rather than to the percentage of the named fish or meat. We understood that overall meat or fish-based content varied across brands, but that due to additional meat and animal derivatives, the overall meat content of cat foods generally exceeded the percentage of the named ingredient. We considered that consumers would therefore infer that the feature product contained significantly less total meat than was the case. Because the claims presented the minimum named-ingredient thresholds as if they described overall fish or meat content, when that was not the case, we considered the ad was likely to mislead consumers as to the overall meat content of the products.
We understood the claim, “if you see the word ‘flavour’ that means there doesn’t have to be any of this ingredient in the product whatsoever” had appeared in error in relation to a product described as “flavoured with”. We considered the claim gave the impression that the featured product did not contain any of the named ingredient, when that was not the case.
For those reasons, we concluded that the claims were likely to mislead.
On that point, the ad breached CAP Code rules 3.1 (Misleading advertising), 3.7 (Substantiation), 3.32 (Comparisons with identifiable competitors) and 3.34 (Comparisons with identifiable competitors).
3. Upheld
As set out in point 1, where ads compared products with identifiable competitors, the basis of the comparison should be objective, and should compare one or more material, relevant, verifiable and representative features. The ad stated, “the common problem with all these brands is they don’t even come close to the 100% whole meat nutrition that your cat needs”. We considered consumers were likely to see the reference to the “100% whole meat nutrition that your cat needs” as an objective claim about cats’ dietary requirements. We also considered that in the context of the claim “You get 100% human grade meat, gently steam cooked to preserve nutrients with none of the fillers or cereals those other brands use to make up for the lack of meat content” that they were also likely to infer that Untamed contained that proportion of whole meat. We further considered “all these brands” was likely to be seen as referring to the cat food products that had previously been held up by the presenter, and therefore as a comparison with identifiable competitors, and also more widely with cat food products commonly available in supermarkets. Consumers were therefore likely to understand from the claim overall that cats needed 100% whole meat diets, that Untamed’s products contained “100% whole meat nutrition” and that the featured brands fell significantly short of that standard.
Untamed had acknowledged that a cat’s diet did not need to be 100% meat in order to be nutritionally adequate and because we had not seen evidence to support the claim that cats needed 100% whole meat, we considered that it was misleading.
We acknowledged that Untamed had intended the claims “made with 100% fresh, real meat & wild fish” and “100% human grade meat” to refer to the quality of their ingredients rather than to the composition of the product. We also understood that Untamed wished to highlight that their own products contained a high proportion of named meat or fish, approximately 60%, in relation to competitor products. However, as with most wet cat foods, we noted broth made up a significant proportion of the recipes. Although broth contained meat derivatives, we considered it would not be seen by consumers as “whole meat”. We therefore considered that the implication that their products contained 100% whole meat was misleading.
We had not seen evidence to show that cats required a specific percentage of meat for their diet to be nutritionally adequate, nor that competitor products “did not come close” to providing the nutrition cats needed. We therefore considered the claim had not been substantiated and that the ad exaggerated the difference in meat content between Untamed and competitor brands.
We welcomed Untamed’s assurance that they would not use the spoken claim again. However, we had not seen evidence to substantiate the claim that cats need 100% whole meat nutrition, that their own product was made up of 100% whole meat, or that the competitor products shown “don’t even come close” to meeting cats’ nutritional needs. For those reasons, we concluded that the claims were misleading.
On that point, the ad breached CAP Code rules 3.1 (Misleading advertising), 3.7 (Substantiation), 3.11 (Exaggeration), 3.32 (Comparisons with identifiable competitors) and 3.34 (Comparisons with identifiable competitors).
Action
The ad must not appear again in the form complained of. We told Untamed Cat Food Ltd to ensure that any comparative claims did not mislead and that they held evidence to support their claims. We also told them to ensure that any claims relating to the meat content of a cat’s diet and their product or rival brands, did not mislead.
