In 2021 the ASA’s Climate Change and the Environment project announced that, in respect of advertisements, it would be starting proactive enquiries into sectors and issues that are likely to have the biggest roles in terms of the UK’s delivery of legally binding environmental targets.
One of the identified areas was the advertising of meat, dairy and plant based alternative food and drink products.
We’re now in a position to outline our recent work around environmental claims in this area.
This includes the main findings from the ASA’s qualitative consumer research that was carried out in 2023, along with key recommendations for actions following our own review into environmental claims currently being made by meat, dairy and plant-based alternative advertisers.
Overall, the ASA’s research and review suggests that there are some specific areas and issues which would benefit from further dialogue and consideration in the coming months, but in general, there is no widespread need for enforcement action to bring claims into compliance with the ad rules.
Key findings from our consumer research:
The use of broad claims like ‘good for the planet’ were usually taken at face value and were less likely to be challenged by the research participants. However, when in the more reflective mindset of the interview, there was some concern expressed that such claims were so general and/or absolute, that they were unlikely to be verifiable – with some participants concerned that such claims could be a brand’s way of making stronger implicit claims without providing any evidence.
The use of certain terminology or visual imagery in advertising contexts could lead to a cascade of associations, imbuing a series of implied attributes into the product or brand that hadn’t been explicitly claimed. For example, using the word ‘natural’ could lead to the assumption that the products were also certified organic.
Visual imagery could also evoke assumptions about environmental, animal welfare, and health benefits. Images of produce which appeared ‘fresh’ could elicit beliefs in much the same way that terms such as ‘natural’ or ‘plant-based’ could. Green, both as a colour and a word, was reported to be powerfully evocative of environmental, animal welfare and plant-based themes, signalling a brand’s environmentally conscious ethos, without explicitly making any claims.
Research participants felt the use of specific terminology like ‘plant-based’ or ‘vegan’ was assumed to be accurate as it was viewed as clear and verifiable. In addition, the consequences of inaccuracy to vegetarian and vegan consumers could be high – and immediate.
Nutritional perception and healthy eating were frequently cited as the primary drivers of dietary preferences and food purchasing decisions, over the environmental impact of food, which was at most a secondary driver of purchase for the majority, and often used as post-rationalisation for choices rather than a catalyst.
Many participants felt that the claims (and counterclaims) made in ads comparing the environmental impact of plant-based products versus animal products effectively cancelled each other out; what’s more, there was a perception amongst some participants that some ads can feel overly ‘preachy’, with claims perceived to vilify a participant’s lifestyle choice (such as the choice to eat meat; these types of claims risked total disengagement from some participants).
Read our consumer research into environmental claims in food advertising.
Key findings from our review
To support our next steps following this research, we conducted a review into the types of environmental claims currently being made in food advertising. This involved us monitoring a sample of thousands of ads through our Active Ad Monitoring system, which utilises AI to process online ads at scale, and human inspection.
We found:
Overwhelmingly, marketing messages within food advertising tend to focus on taste, nutrition, and price; these findings corroborated what emerged out of the consumer research.
Some evidence of “sustainable” claims being used in a number of different ways within the overall context of food production, occasionally unqualified, and in a way which has the potential to be misleading if presented in too absolute terms. It should also be noted, however, that we found that many advertisers – both large and small – had what appear to be comprehensive sustainability frameworks and initiatives in place that support such claims.
Some (albeit limited) evidence of the emerging trend towards “regenerative farming” claims.
Some evidence of breaches of existing ASA precedent and Guidance, for instance in cases where advertisers are making comparative environmental impact claims without suitably qualifying the basis for those claims.
We were pleased to find no widespread evidence to indicate that meat, dairy and plant-based food advertisers are routinely using ‘green’ or ‘natural’ imagery in obviously misleading ways.
Insights and next steps
Our consumer research indicates that, while nutritional impact, habit/taste and occasionally affordability have a more direct impact on dietary preferences and purchasing decisions, the power of environmental claims and terminology in food advertising is likely to lie in the public’s uncritical acceptance, and the positive associations such claims have on brands.
In light of the key findings from this research, and in addition to the findings from our own review, here are some key recommendations that we will take forward in 2024:
In order to provide assistance and guidance to the industry regarding the conclusions of this research and its own review, the ASA will continue its engagement with the CMA, Defra, and industry stakeholders on its findings, and CAP will also be providing further guidance to industry this summer in the form of a series of Insight Articles to be published on the ASA website. These Insight Articles will expand upon some of the key themes which emerged out of the consumer research and our own review, including ‘green’ and ‘natural’ imagery, as well as sustainability and regenerative farming-related claims. You can sign up to receive CAP’s Insight Articles here.
From July 2024 the ASA and CAP proposes additional monitoring and follow-up engagement to address instances of clear-cut breaches of established positions already set down in existing ASA Rulings and Guidance, with the potential to formally investigate other, less clear-cut instances of non-compliant advertising within this sector, with a particular focus on unqualified sustainability and comparative environmental impact claims.
Although this review found little evidence of obviously problematic examples of ‘green’ or ‘natural’ imagery in the sample analysed, the ASA will continue to monitor for potential misleading ‘green’ imagery issues in 2024, given the strong consumer research findings.
In order to better understand what regenerative farming involves (and any potential emerging issues around it), the ASA will engage with industry and other partners on the issue and thereafter produce guidance to assist businesses to make claims that are more likely to be compliant with the advertising rules.
Additionally, we will continue to work in partnership with the Department for Environment, Food & Rural Affairs (DEFRA) and the Institute of Grocery Distribution (IGD) as they work with industry to gather information to inform their recommendations to the UK government that cover the label, methodology, data, and governance in preparation for consultation on a food eco-labelling scheme.
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