Advertisment
A television advertisement featured a female rugby player speaking about Irish grass and dairy. The voiceover stated:
“I spend a lot of time on grass. I know the feel of it and yes, I know the taste of it. We’re world famous for our grass which is why we’re world famous for our dairy produce too. Because our beautiful and rich green grass lies at the heart of our naturally nutritious, sustainably produced milk.
Sure, why else do you think we play in green.”
Text on screen stated:
“Milk is a naturally rich source of protein and calcium which support the normal maintenance of bones. Irish cows are predominantly grass-fed and 99% of the water used to produce milk is supplied by natural rainfall.”
The end frame of the advertisement included the following:
“Nourished from the ground up”.
Complaint
Three complainants objected to the advertising.
The complainants considered it was misleading and ‘greenwashing’ to claim milk was sustainably produced because of the damage the dairy industry caused to the environment. The complainants said that Irish agriculture was the single biggest contributor of greenhouse gas emissions in Ireland and caused the greatest amount of biodiversity loss in Ireland due to the national herd and because of the use of synthetic nitrogen fertilisers. They referred to the EU Joint Research Centre ’s Report from 2010 which they said stated that Ireland had the fourth highest CO2 emissions in the EU for milk production.
Another complainant said that while dairy production in Ireland may be more sustainable than other countries, it was misleading to say that it was sustainable in Ireland given that the Climate Action Plan included a requirement that farming emissions be reduced by 25%.
Response
The advertisers said that sustainability comprised three distinct elements, economic, social, and environmental and that the definition of ‘sustainable’ was described as something that was able to be sustained economically, socially and environmentally and that all of those criteria needed to be taken into account when classifying anything as ‘sustainable’.
They said that Irish dairy products were exported to 130 countries and delivered €6.8bn to the Irish economy each year and that Irish dairy sustained the livelihoods of 17,500 family-
run dairy farms and supported 54,000 Irish jobs. They also said that dairy was an important part of a balanced diet.
In regard to the complaints that milk wasn’t sustainably produced, they said that agriculture was tasked with achieving a 25% reduction in emissions by 2030 and as part of this, the dairy industry was implementing new technologies and farming practices (in the areas of breeding, feeding, pasture management, soil management and fertiliser use) to address the target, and that progress was being made, particularly as Irish agricultural emissions reduced in 2022 according to the EPA.
The advertisers said that there were specific farming initiatives in place on water quality, such as precision fertiliser spreading, riparian margins, using trees (willows) and plants (reeds) to filter farmyard run-off.
They also said that one of the fundamental priorities of the Paris Agreement of 2015 was safeguarding food security and ending hunger, noting the particular vulnerabilities of food production systems to the adverse impacts of climate change. The objective was to reduce the environmental impact to an acceptable level within the constraints of economically viable, high quality, safe and nutritious food production.
They said that the ‘sustainably produced’ claim was based on substantiated data and assessments of value across the three areas of sustainably, environmental, economic and social and that the claim was substantiated and evidenced by data and assessments of value that were freely available, and as such the consumer needed no further knowledge to assess it. They said that the claim was supported by data from (amongst other sources) the Central Statistics Office and the Environmental Protection Agency (EPA).
The advertisers referred to the fact that greenhouse gas emissions from agriculture reduced by 1.2% according to EPA, with one of the reasons for this being a reduction in fertiliser use. According to the European Union Joint Research Council (EUJRC) report, Ireland had the most, or second most, greenhouse gas-efficient production system in Europe (however, they did accept that this data was in need of updating as it was from 2010).
They said that the practice of stitching clover into Irish dairy pastures was gaining traction and was increasingly widespread, with 80% of re-seeding incorporating clover. They said that white clover locked nitrogen into the soil, reducing the requirement for chemical nitrogen fertiliser and that 25-30% clover reduced the need for fertiliser by around100kg N per hectare.
Conclusion
Complaints Upheld
The Complaints Committee considered the detail of the complaints and the advertisers’ response.
The Committee noted the advertisement had included the statement “sustainably produced milk” and that the complainants had all objected to the advertisement on the grounds that the use of ‘sustainably’ was misleading given that they believed Irish dairy farming caused environmental damage. The Committee were aware that sustainability involved more than just environmental issues , and while they noted the steps taken by Irish dairy farmers to be more sustainable, the advertisement had included an absolute claim that milk was ‘sustainably produced’. In the absence of a qualification or evidence for the claim, the Committee considered the claim was in breach of Sections 4.1, 4.4, 4.9, 4.10, 15.2, 15.5 and 15.6 of the Code
Action Required:
The advertising must not reappear in its current form. The Committee reminded advertisers not to make absolute claims without qualification unless evidence is provided for the claim.
