Advertisment
Television Advertising:
A television advertisement featured various images from farmland and included the following statements:
“What if someone nurtured nature. Planted hedgerows to make homes for the birds and the bees. Quietly helped reduce emissions by stitching clover into grass and working together with the land to produce food in a more sustainable way? What if that someone was already here? And we are thousands strong.”
On screen text during the advertisement stated:
“What If? Someone Planted Hedgerows/ Reduced Emissions/ Working Together With the land/ 96% of Dairy Farmers Have signed up to sustainability programmes.”
Radio Advertising:
Two radio advertisements featured a farmer discussing the climate efficiency of Irish dairy and the steps they were taking to reduce their farms impact on the environment.
Advert 1:
“Hello, I’m [name redacted] and I’m a dairy farmer from [county redacted]. Irish dairy has one of the lowest dairy carbon footprints in the World. Litre for litre, Irish milk has a footprint half the size of milk produced in most other countries. Our climate is ideal for dairy and we’re farming more efficiently every year. We’re using science and technology to reduce our footprint even further. Reducing Irish dairy emissions by 25% by 2030 is our goal. I’m speaking on behalf of the National Dairy Council, everyone’s dairy.
Advert 2:
“Hello, I’m [name redacted] and I’m a dairy farmer from [county redacted]. As a farmer it’s my job to care about the environment, managing my hedgerows and field edges encourages bio-diversity and helps protect water quality for everyone. Using less fertilizer and regular soil testing are other steps we’re taking to minimise our impact on Irish rivers, lakes and waterways. It can take years for improvements to show but the things we’re doing are making a difference. I’m speaking on behalf of the National Dairy Council, everyone’s dairy.”
Press:
A sponsored article on a newspaper’s website featured the headline:
“Ireland has a lower carbon footprint per litre of milk than almost any other country”.
Website:
A webpage on the advertisers’ website included the following statements:
“Lowest. Litre for litre, Irish milk has one of the lowest carbon footprints of all milk produced anywhere.”
“70% of dairy farmers using low-emission manure spreading technology”.
“80% of reseeding incorporated clover.”
Complaint
Seven complaints were received regarding the various advertisements. The complainants raised the following issues:
Issue 1 – Press and Radio Advert 1:
The complainants did not consider that the claim in the press advertisement that Ireland had a lower carbon footprint per litre of milk than almost any other country or the claim in the radio advertisement that Irish dairy had one of the lowest dairy carbon footprints in the World; litre for litre, Irish milk had a footprint half the size of milk produced in most other countries, could be substantiated as they did not believe that Irish dairy farming was sustainable. The complainants also considered that no basis for the claim had been included in the advertising.
One complainant considered that the claim made was based on a study from 2010 which they considered had been contradicted in 2011 as referred to by an article that had been published online.
Issue 2 – Television Advertisement:
Complainants objected to the television advertisement on the grounds that it was ‘greenwashing’. One complainant, a small farmer themselves, stated that agriculture was the highest carbon dioxide emitting sector in Ireland and that emissions were still rising today. Another complainant stated that since the abolition of milk quotas, dairy farming had led to environmental damage, including negative effects on Irish water body quality. A further complainant considered that statements such as ‘Quietly helped reduce emissions by stitching clover into grass’ were vague intangible declarations.
Issue 3 – Television Advertisement:
One complainant considered that the claim that 96% of dairy farmers had signed up to sustainability programmes was misleading by ambiguity given that no information had been provided as to whether the sustainability programmes had yielded any concrete environmental improvements.
Issue 4 – Press Advertisement:
A complainant considered that the claim Ireland had a lower carbon footprint per litre of milk than almost any other country was misleading given that an article from another publication had positioned Ireland as 10th on a global list of countries carbon milk footprint.
Response
The advertisers said that the campaign aimed to build a link between farmers and consumers, through stories of changing farming practices, of technological innovation and of tangible results, backed by substantiated fact.
Issue 1 – Press and Radio Advertisement:
The advertisers said that litre for litre, Irish milk had a lower carbon footprint that that of milk produced almost anywhere else at around 0.97kg CO2-eq, compared to an average of over 2kg in some other countries (1)(2) They said that their campaign focused on environmental sustainability, that is what is being done to improve farming practices and mitigate the industry’s environmental impact. They said that social, economic, and cultural sustainability were also important, and the milk produced on 17,500 Irish dairy farms sustained 60,000 jobs in the country’s economy and delivered a €6.8bn contribution to Ireland’s economy each year.
They said that farmers across the country were investing in new technologies and methodologies designed to mitigate their environmental impact; such as low-emission slurry-spreading reduced 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 (by up to 40% per hectare) meaning less run-off into waterways. They also said that by moving fences out from hedgerows and watercourses to increase field margins (the areas between the grazing pasture and the field boundary) left space for nature and helped to keep pesticides, fertilisers, and slurry away from watercourses and hedgerows.
In response to the reference to the online article that one of the complainant’s referred to, they said that the article was discussing data from 2010 which was an old study and was not the study they had based their claim on.
Issue 2 – Television Advertisement:
The advertisers said that agriculture emitted very little carbon dioxide. They said that the main greenhouse gases from agriculture were biogenic methane (CH4) and nitrous oxide (NO2). They said, according to the EPA, agricultural emissions were decreasing, and they provided the following extract from an EPA report. “Agriculture: Emissions overall decreased by 1.2 per cent or 0.29 Mt CO2eq in 2022. A welcome decrease of 14 per cent in nitrogen fertiliser use, to 343,000 tonnes, made significant progress towards the 330,000-tonne target for 2025 in the Climate Action Plan and resulted in 0.44 Mt CO2eq less emissions from agriculture. These reductions offset the impact of higher dairy cow numbers which increased for the 12th successive year. Total milk production increased by 0.7 per cent in 2022, with milk output per cow decreasing slightly , -0.2 per cent.” (3)
The advertisers said that water quality was a major focus for Irish farmers all over the country and that they were employing a variety of measures to reduce their impact and they considered it was showing results. In regard to concerns around agricultural runoff being a contributor to changes in water quality in Ireland, they said it was being addressed by reducing fertiliser usage, precision fertiliser application, riparian margins and use of trees and plants to filter farmyard runoff. They said that the last EPA water quality report (4) showed an increase in water bodies in the top category (High), and reduction in those in the bottom two categories (Poor and Bad), although it also showed an increase in water bodies in the third from bottom category (Moderate) and a decrease in those in the second from top category (Good). They said that the decrease in water quality was matched by the increase in water quality elsewhere.
They said that hedgerows and woodlands were not being destroyed to expand dairy farms and said that schemes such as the Government run Agri-Climate Rural Environment Scheme (ACRES) were actively encouraging farmers to plant trees and hedgerows (5).
The advertisers said that stitching clover into traditional rye grass pastures was now a widespread dairy farming practice and was backed by years of scientific research at Teagasc Moorepark and UCD Lyons Farm (amongst other academic and research centres). They said that clover was proven to ‘fix’ nitrogen in the soil, reducing the need for inorganic nitrogen fertilisers by as much a 40% per hectare, reducing NO2 emissions and mitigating nutrient run-off into waterways. They said that Irish dairy farmers were demonstrably ‘quietly reducing emissions and that the EPA’s 2023 report showed that agricultural emissions overall decreased by 1.2 per cent or 0.29 Mt CO2eq in 2022 (6).
Issue 3 – Television advertisement:
The advertisers said that progress against agriculture’s emissions-related environmental targets was measured and reported on by the Environmental Protection Agency with their finding in 2022 stating:
“Agriculture: Emissions overall decreased by 1.2 per cent or 0.29 Mt CO2eq in 2022. A welcome decrease of 14 per cent in nitrogen fertiliser use, to 343,000 tonnes, made significant progress towards the 330,000-tonne target for 2025 in the Climate Action Plan and resulted in 0.44 Mt CO2eq less emissions from agriculture. These reductions offset the impact of higher dairy cow numbers which increased for the 12th successive year. Total milk production increased by 0.7 per cent in 2022, with milk output per cow decreasing slightly (-0.2 per cent)” (7).
Issue 4 – Press Advertisement:
The advertisers referred to the finding cited in the Journal of Dairy Science that the carbon footprint of a litre of Irish milk stood at around 0.97kg CO2-eq, compared to an average of over 2kg elsewhere (8).
They also referred to a paper which demonstrated that the global average for milk’s carbon footprint was 2.4 CO2-eq/kg (9).
(1) Journal of Dairy Science 2022 – ‘Life cycle assessment of pasture-based dairy production systems: Current and future performance’
(2) Greenhouse Gas Emissions from the Dairy Sector. Report by the Food and Agriculture Organisation of the United Nations Annual Production and Health Division.
(3) https://www.epa.ie/news-releases/news-releases-2023/irelands-2022-greenhouse-gas-emissions-show-a-welcome-decrease-but-much-work-remains-to-be-done.php#:~:text=Agriculture%20emissions%20decreased%20by%201.2,fuel%20and%20milder%20weather%20evident.
(4) https://www.epa.ie/publications/monitoring–assessment/freshwater–marine/WaterQuality_SummaryReport.pdf
(5) https://www.gov.ie/en/service/f5a48-agri-climate-rural-environment-scheme-acres
(6) https://www.teagasc.ie/media/website/publications/2019/Moorepark-clover-study-update.pdf
(7) https://www.epa.ie/news-releases/news-releases-2023/irelands-2022-greenhouse-gas-emissions-show-a-welcome-decrease-but-much-work-remains-to-be-done.php#:~:text=Agriculture%20emissions%20decreased%20by%201.2,fuel%20and%20milder%20weather%20evident.
(8) Journal of Dairy Science 2022 – ‘Life cycle assessment of pasture-based dairy production systems: Current and future performance’
(9) Greenhouse Gas Emissions from the Dairy Sector. Report by the Food and Agriculture Organisation of the United Nations Annual Production and Health Division
Conclusion
Complaints Upheld In Part
The Complaints Committee considered the detail of the complaint and the advertisers’ response.
Issue 1: Complaints Upheld:
The Committee noted that the claims made in both advertisements were Ireland had a lower carbon footprint per litre of milk than almost any other country and Irish dairy had one of the lowest dairy carbon footprints in the World; litre for litre, Irish milk had a footprint half the size of milk produced in most other countries, which the advertisers believed was evidenced by the fact that the carbon ‘hoofprint’ in Ireland was much lower than other countries. The Committee noted that the advertisers had referred to two studies, one published in 2022 which included a reference to the carbon ‘hoofprint’ of dairy in Ireland as being 0.97kg CO2-eq, while the second, published in 2010, included a statement that the global average for carbon footprint was 2.4 CO2-eq. The Committee also noted that the study published in 2022 had also included a reference to the carbon footprint of dairy in New Zealand being at a lower figure to that of Ireland. While the Committee noted the difference in the carbon footprint/’hoofprint’ between Ireland and the global average, the study referencing the global average was dated from 2010, some 13 years earlier, and that no details had been provided as to where the global average figure had been sourced. The Committee considered that a study from 2010, without evidence of the average global figure not having changed, was not sufficient evidence for the claims made in the advertising. In the circumstances, the Committee considered that the claims objected to at Issue 1 were in breach of Sections 4.1, 4.4, 4.9, 4.10, 15.2, 15.5 and 15.6 of the Code.
Issue 2 – Statement:
The Committee noted the complainants considered that the television advertisement was ‘greenwashing’ because they considered that agriculture was a significant emission emitter. The Committee considered the evidence provided by the advertisers regarding their claims. The Committee considered, that in line with the Code, a statement was warranted in this case.
The Committee noted that the advertisement had asked a number of questions in relation to a number of activities, asking “what if” someone was doing something, followed by an on-screen statement that 96% of dairy farmers had signed up to sustainability programmes. The Committee reflected on the potential take-out of consumers regarding the activities referred to and the claim that 96% of dairy farmers had signed up to sustainability programmes. While the Committee considered that, on balance, the advertisement had not made any explicit claims as to the effects of the activities referred to, the reference to sustainability programmes implied that they had an impact. They noted that no information had been provided in the advertisement as to how farmers who sign up to the sustainability programme actually helped the environment. They considered the lack of information had potential to mislead. The Committee considered that advertisements should not refer to sustainability programmes without directing consumers to a source of information that provided an explanation as to how the impact of such programmes have helped and/or were intended to help the environment.
Issue 3 – Statement:
The Committee considered, that in line with the Code, a statement was warranted in this case.
The Committee noted that the complainant considered that the results of the farmers signing up to sustainability programmes should have been included in the advertisement. The Committee noted that the claim in the advertisement was that 96% of dairy farmers had signed up to sustainability programmes, and no claim had been made as to what the impact of those farmers signing up had been made. As with Issue 2, the Committee considered that advertisements should not refer to sustainability programmes without directing consumers to a source of information that provides an explanation as to how the impact of such programmes have helped and/or were intended to help the environment.
Issue 4 – Complaints Upheld:
The Committee noted that the advertisers had referred to two studies, one published in 2022 which included a reference to the carbon ‘hoofprint’ of dairy in Ireland as being 0.97kg CO2-eq, while the second, published in 2010, included a statement that the global average for carbon footprint was 2.4 CO2-eq. The Committee also noted that the study published in 2022 had also included a reference to the carbon footprint of dairy in New Zealand being at a lower figure to that of Ireland. While the Committee noted the difference in the carbon footprint/’hoofprint’ between Ireland and the global average, the study referencing the global average was dated from 2010, some 13 years earlier, and that no details had been provided as to where the global average figure had been sourced. The Committee considered that a study from 2010, without evidence of the average global figure not having changed, was not sufficient evidence for a claim made in the advertising 13 years after the study, that “Ireland has a lower carbon footprint per litre of milk than almost any other country”. In the circumstances the Committee considered that the press advertisement 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 should not reappear in its current form.
The Committee advised that any references to sustainability programmes in advertising include a direction to a source of information providing an explanation as to how the programmes were helping or intended to help the environment.
