Food & Non-Alcoholic Beverages

A webpage on the advertisers’ website promoting the Farmer Ambassador Programme, included the following statements:

“Irish dairy has the most greenhouse gas emissions-efficient production system certainly in Europe and possibly in the world.

Meeting growing international demand for dairy by producing it in Ireland is the best way of tackling the global climate change challenge.”

Issue 1:
The complainant considered that the claim “Irish Dairy has the most greenhouse gas emissions-efficient production system certainly in Europe and possibly in the world” was misleading as they believed that Ireland ranked one of the highest in Europe for greenhouse gas emissions, ranking 47th out of 59 on actions to curb greenhouse gas emissions.

Issue 2:
The complainant considered that the claim “Meeting growing international demand for dairy by producing it in Ireland is the best way of tackling the global climate change challenge” was misleading as they believed that Ireland ranked one of the highest in Europe for greenhouse gas emissions, ranking 47th out of 59 on actions to curb greenhouse gas emissions.

The advertisers said that the advertising campaign was telling the story of real Irish farmers and the actions they were taking to take care of the land they farmed. They said that Ireland was unique in having a large number of small family-owned farms and traditionally, Irish farmers passed the land onto the next generation and therefore, they had a genuine interest in protecting the land for generations to come.

Issue 1:
They said that Irish grass-based dairy and beef production systems were very carbon efficient. They referred to an EU study(1) that rated Irish dairy production as the most carbon efficient in the EU. They said that Ireland was one of the few countries in the world to have a predominantly pasture-based production system, with cows out in the fields between 240 and 300 days a year and 95% of their diet was grass.

Issue 2:
The advertisers said that litre for litre, Ireland was one of the best countries in the world at producing dairy, with the carbon hoofprint of a litre of milk stood at around 0.97kg CO2-eq, compared to an average of over 2kg elsewhere (2) (3). They said that millions of people around the world relied on dairy as part of a nutritious, balanced diet, and demand for dairy products was buoyant and growing. They said that moving dairy to other countries could only result in a global increase in greenhouse gas emissions, otherwise known as ‘carbon leakage’.

They said that farmers across the country were investing in new technologies and methodologies designed to offset their carbon footprint; such as low-emission slurry-spreading reduces ammonia emissions, while the switch to low-emissions fertiliser had the potential to reduce total farm emissions by up to 8 percent; and clover in the pasture significantly reduced the need for chemical fertiliser meaning less run-off into waterways and a significantly lower carbon footprint for Ireland’s herd. They said that beyond production, their farmers were dedicated to the environmental wellbeing of their farms, moving fences out from hedgerows and watercourses to increase field margins, the areas between the grazing pasture and the field boundary, to leave space for nature and to help to keep pesticides, fertilisers and slurry away from watercourses and hedgerows.



(1) https://www.teagasc.ie/media/website/publications/2019/Bord-Bia-Dairy-Carbon-Navigator-LR5.pdf
(2) Journal of Dairy Science 2022 – ‘Life cycle assessment of pasture-based dairy production systems: Current and future performance
(3) Greenhouse Gas Emissions from the Dairy Sector. Report by the Food and Agriculture Organisation of the United Nations Annual Production and Health Division.

The Complaints Committee considered the detail of the complaint and the advertisers’ response.

Issue 1 – Upheld:
The Complaints Committee noted that the claim made was that ‘Ireland had the most greenhouse gas emissions-efficient production system certainly in Europe and possibly in the world’ which the advertiser had said was evidenced in an EU study. As evidence, the advertisers provided a copy of a document titled ‘The Dairy Carbon Navigator’ which referred to the EU study but did not identify it. The Committee noted that the document provided was a guidance document for farmers on how to improve carbon efficiency and lower agricultural greenhouse gases on their farms and included a carbon navigator input sheet. While the Committee noted the document had referred to the results of an EU study that rated Irish dairy production as the most carbon efficient in the EU, no evidence had been provided that Ireland had the most greenhouse gas emissions-efficient production system in the EU or “possibly in the world”. The Committee noted the requirements of the Code that advertisers should hold evidence for claims made in their advertising. In this case, the Committee did not consider that the documentation provided had substantiated the claim made in the advertising and therefore, considered that the advertising was in breach of Sections 4.1, 4.4, 4.9, 4.10, 15.2, 15.5 and 15.6 of the Code.

Issue 2 – Upheld:
The Complaints Committee noted the claim made was “meeting growing international demand for dairy by producing it in Ireland is the best way of tackling the global climate change challenge” which the advertisers believed was evidenced by the fact that the carbon ‘hoofprint’ in Ireland was much lower than other countries. The Committee noted the advertisers had provided two documents, one which stated that the carbon ‘hoofprint’ of dairy in Ireland was 0.97kg CO2-eq, while the second stated that the global average for carbon footprint was 2.4 CO2-eq. While the Committee noted the difference in the carbon footprint/’hoofprint’ between Ireland and the global average, they noted that the study referencing the global average was dated from 2010, some 13 years earlier and no details had been provided as to where the global average had been sourced. The Committee did not consider that evidence had been provided as to how producing dairy in Ireland to meet the international demand for produce was the best way of tackling the global climate change challenge. In the circumstances, the Committee considered that the advertising was in breach of Sections 4.1, 4.4, 4.9, 4.10, 15.2, 15.5 and 15.6.



Action Required:
The advertising should not reappear in its current form unless independent evidence was provided for the claims made.