The ASA publishes its research on the influence of environmental claims in food and drink marketing

April 25, 2024
Fresh produce

On 18 April 2024, the ASA published its research on the influence of environmental claims in food and drink advertising on consumers. The ASA focused on the advertising of meat, dairy and plant-based products as part of its stated aim of making proactive enquiries into those sectors and issues that are likely to have the biggest impact on the UK’s delivery of legally binding environmental targets.

This latest research is all part of the ASA’s ‘Climate Change and Environment’ project, which has already seen the ASA research people's understanding of green disposal terminology, such as 'recycled', 'biodegradable' and 'compostable'.

While the ASA’s latest research has concluded that there is no large-scale enforcement required to bring environmental claims in food and drink advertising into compliance with advertising rules, the ASA does make recommendations which will be of relevance to all sectors. The full report can be found here.

ASA’s key findings

  • The ‘halo effect’: The use of words such as ‘natural’ and ‘plant-based’ along with images of fresh produce can lead consumers to assume that products are eco-friendly or have certain health benefits. Described as a ‘halo effect’, the ASA’s research found that assumptions were made that had not been explicitly claimed in the advert.[1] Similarly, use of the colour and word ‘green’ can lead to expectations that a brand might have an environmentally friendly ethos, in the same way that the word ‘natural’ might lead the consumer to believe that the product is also certified organic.
  • General assumptions: While certain words in adverts might impact a consumer’s perspective, adverts containing general assumptions were found to be accepted without challenge by the consumer – largely because consumers believe advertising is highly monitored and regulated in the UK. The claim ‘good for the planet’ was one such claim. Similarly, words like ‘plant-based’ or ‘vegan’ with a narrow and specific meaning that could be easily verified, are likely to be perceived as accurate statements by consumers. The addition of statistics or technical words further reassures consumers of an advert’s correctness.
  • Main factors in deciding which produce to buy: Despite the general acceptance by consumers of environmental claims, they do not currently play the main role in a consumer’s decision to purchase a product. Instead, the primary considerations are taste, nutritional value, health benefits and price. Interestingly, nutritional and health claims led to scepticism amongst consumers in a way that was not seen in relation to environmental claims.
  • ‘Regenerative farming’ claims: The ASA’s research identified a trend towards ‘regenerative farming’ claims and wants to engage with industry and other partners on the issue to ensure those claims are compliant.

Impact for advertisers

It is interesting to see what consumers are likely to accept as fact without challenge, because that also highlights those areas where advertisers need to take particular care not to mislead consumers.

When given the chance to reflect on general assumptions, for example, participants in the research expressed some concern that the claims were so general and/or absolute and could enable a brand to make stronger, implicit claims without providing any evidence. Equally, without standardisation or regulation of some terminology, such as ‘natural’ and ‘sustainable’, consumers found it difficult to make comparisons across brands, because those definitions are largely in the discretion of the advertiser.

The ASA have acknowledged that 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, and that they need to continue to monitor compliance in this area so that public trust is not misplaced.

Next steps

Advertisers can expect the ASA to continue to closely monitor the potential for misleading ‘green’ issues, given the strong consumer research findings. The ASA have already stated that, from July 2024, there will be additional monitoring and follow-up engagement in order to address instances of clear-cut breaches of established positions already set down in existing ASA rulings and guidance. They may also formally investigate other, less clear-cut, instances of non-compliant advertising in this sector, focussing on unqualified sustainability claims and comparative environmental impact claims.  

Further guidance to advertisers is also anticipated to be published over the summer via a series of Insight Articles on the ASA website which will expand on key themes from the research – including, for example, the use of ‘green’ and ‘natural’ imagery.

What is clear is that, in order to maintain public trust in advertising and its regulation, the ASA’s scrutiny in this space is not going away.

Caroline CopelandCaroline Copeland
Caroline Copeland
Caroline Copeland
Catherine CloverCatherine Clover
Catherine Clover
Catherine Clover
Trainee Solicitor

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