The ASA has been investigating the advertising of meat, dairy and plant-based alternative food and drink products - both carrying out research with consumers and reviewing relevant adverts. This can be quite an emotive area, both for environmental and animal welfare reasons. The ASA has now issued the main findings of its research, alongside its key recommendations.
Key findings from the consumer research
- Consumers generally took broad claims like ‘good for the planet’ at face value, but they also acknowledged that they were so general and/or absolute, that they were unlikely to be verifiable and that brands could use them to make strong 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, for example, images of produce which appeared ‘fresh’. 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.
- The use of specific terminology like ‘plant-based’ or ‘vegan’ was assumed to be accurate as it was viewed as clear and verifiable.
- The main drivers of food purchasing decisions are nutritional perception and healthy eating; the environmental impact of food is secondary.
- Many participants in the research felt that ads comparing the environmental impact of plant-based products versus animal products effectively cancelled each other out. They said 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).
Key findings from the ASA's review of environmental claims currently being made in food advertising.
The ASA found:
- Overwhelmingly, marketing messages within food advertising tend to focus on taste, nutrition, and price.
- 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. However, many advertisers had 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 rulings and guidance, eg comparative environmental impact claims without suitably qualifying the basis for those claims.
- There was 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
The ASA intends to:
- Engage with the CMA, Defra, and industry stakeholders on its findings, and CAP will also be providing further guidance to industry, expanding on some of the key themes, including ‘green’ and ‘natural’ imagery, as well as sustainability and regenerative farming-related claims.
- From July 2024, carry out additional monitoring and follow-up engagement to address instances of clear-cut breaches of ASA and CAP rules, 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.
- Continue to monitor for potential misleading ‘green’ imagery issues.
- Produce guidance on regenerative farming.
- Work with Defra and the Institute of Grocery Distribution regarding a food eco-labelling scheme.