Advertisment
A post and video appeared on the advertiser’ X (Twitter) account:
The post stated:
“Irish dairy is different, and on #worldmilkday we celebrate it.
To Ireland, where dairy is produced in the traditional way. It’s sustainable, natural and nutritious of course. Discover the story behind every glass at “ [link to website]
The video in the post featured various scenes showing agricultural land, a farmer walking in a field and grass being examined. Other scenes featured dairy products, milk being poured into a glass and consumed, cheese being cut and put on a sandwich and yoghurt being eaten.
The voiceover of the video stated:
“World Milk Day. It’s a day we raise a glass to the good things in life. To Ireland, where dairy is produced in the traditional way. More sustainable, more natural, and nutritious of course. To the pastures, the climate, the grass-fed cows. To farmers working in harmony with nature, to give harmony with nature, to give us dairy tomorrow.
To milk itself, rich in protein and nutrition. To the energy and vitality, it gives us throughout our lives. Irish dairy is different, and on World Milk Day, we celebrate it. Naturally good, naturally delicious.”
Complaint
Four complainants objected to the advertising on the following grounds:
Issue 1:
The complainants considered that the claim that Irish dairy was sustainable was misleading. They considered that there was no evidence-based study that would substantiate the claim and that according to EPA, agriculture was Ireland’s greatest polluter.
One complainant said dairy farming accounted for 35% of Ireland’s GHG emissions and was the single largest source of Water framework directive (WFD) surface water pressures in the country.
Issue 2:
The complainants considered that the claim that dairy was produced in a traditional way was misleading as traditional farming methods did not cover the large-scale farming that was done in Ireland. They said that the advertisement relied on the stereotypes of ‘traditional’ farming and misled consumers into thinking farming had very few to no detrimental effects on the environment.
Response
The advertisers said that the complaints related to the wording of the Tweet, rather than the whole communication. They said that the Tweet must be looked at in context, as the initial wording was a short piece of information as per the definition of a Tweet and that the wording of the video should be looked at in conjunction with the wording of the Tweet. They said that the Tweet invited the viewer to follow the link to a website where further information was given.
Issue 1:
In response to the issue raised, they said that the link in the Tweet led to the Irish dairy section of their website where a user could access more information. For example, they said that under the ‘sustainable Irish dairy’ heading it stated that farmers not only adhered to the EU’s high food safety standards, but that through membership of Origin Green they did more to serve the global market.
They said that the website referred to greenhouse gas emissions (GHG) and stated that Ireland was one of the lowest globally from a GHG emissions intensity perspective, at an average of 0.91kg CO2 equivalents per kg output, seeing a 9% reduction in the last 8 years.
They said that the website also provided a table titled ‘tracking positive change’ which showed that the dairy carbon footprint had reduced from 0.93kg in 2019 to 0.92kg in 2020 and to 0.91kg in 2021. As such, they said it showed that dairy in 2021 was more sustainable than previous years. They also said that the website noted the ongoing efforts of farmers to become even more sustainable in the future, such as the increased use of low emission slurry spreading technology as well as changes in the type of fertilisers being used and the incorporation of clover into reseeding programmes.
They said that the narrative in the video, which was both in text as well as in audio format, stated that dairy was ‘more sustainable, more natural and nutritious of course’, and that the very use of the word ‘more’ necessarily meant that the statement was qualified or that it must be read by reference to something else. They said that given the 280-character limit for a Tweet, it would not be possible for them to set out the complexities and nuances of their position and the data available. They said that in order to overcome the limitations of the medium, the Tweet invited the user to access their website where additional information was provided. They considered that this was important given that an advertisement is assessed as a whole and in context. They said that research had shown that Irish dairy production was more sustainable now than it was in the past and was more sustainable than dairy produced elsewhere.
The advertisers said that it was incorrect to say that dairy accounted for 35% of Ireland’s GHG emissions as it was agriculture generally that accounted for 35% of Ireland’s GHG emissions and dairy was only a subset of agriculture. They said that while not seeking to downplay that figure, it was reflective of the absence of a heavy manufacturing sector in Ireland and the fact that, as a nation, Ireland was a significant exporter of agricultural commodities deriving from ruminant animals.
To evidence that dairy production in Ireland was becoming more sustainable, the advertisers referred to Teagasc’s National Farm Survey 2019 Sustainability Report which noted that the CO2 per kg of Fat and Protein Corrected Milk emissions reduced by almost 9.7% between 2011 and 2019 using Intergovernmental Panel on Climate Change methodology.
They said that the Teagasc 2022 farm survey (published Oct 2023) illustrated the continuing adoption of actions to address greenhouse gas emissions, particularly by dairy farmers. For example, in 2022, 75% of slurry on dairy farms was applied to land using Low Emissions Slurry Spreading equipment. They said that Teagasc pointed out that even though herd sizes had increased on dairy farms in 2022, on average greenhouse gas emissions on a whole farm and per hectare basis declined, largely due to a significant decrease in chemical nitrogen fertiliser use on dairy farms. According to Teagasc greenhouse gas emissions by dairy farmers fell by 0.2 tonnes per hectare.
The advertisers said that 16,000 Irish dairy farmers were active members of their Sustainable Dairy Assurance Scheme, which was a voluntary scheme operating under Origin Green, Ireland’s national food sustainability programme. They said that the scheme was built on best practice in farming and processing, current legislation, relevant industry guidelines and international standards and was accredited to the ISO 17065/2012. Among the primary objectives of that standard are that (i) milk processors and customers of dairy products be able to demonstrate that milk is produced on certified farms which meet the highest Bord Bia standards including those for environmental protection, animal welfare, traceability, and food protection, and (ii) to provide proof the milk produced on certified farms is produced under an ISO accredited sustainability and quality assurance scheme.
As part of the scheme, they said that over 9,000 Sustainable Dairy Assurance Scheme audits had been carried out every year and since 2014, 80,000 carbon footprints had been calculated for certified Irish dairy farm members as part of the Bord Bia Sustainable Quality Assurance Scheme. In that time period the carbon footprint from Sustainable Dairy Assurance Scheme members had fallen by 9%, with the average carbon footprint of a certified dairy member being 0.91 kg CO2eq/kg for fat and protein corrected milk.
The advertisers said that Sustainable Dairy Assurance Scheme farmers were actively engaging in sustainable farming practices to improve nutrient management and reduce greenhouse gas emissions, examples of such practices were (i) using low emission slurry spreading technology to apply manure, (ii) soil testing, and (iii) improving soil health by applying lime and clover incorporation into grassland swards. Additionally, there had been a number of national initiatives to increase awareness and assist dairy farmers to make greater efforts to become increasingly sustainable into the future, such as the establishment of Dairy Sustainability Ireland, and Smart Farming (which was run by the Irish Farmer’s Association and the Environmental Protection Agency).
They said that Irish dairy production was more sustainable than dairy production elsewhere and that according to Teagasc, whose research showed that when GHG emissions allocated to dairy production were expressed per kilogramme (kg) of milk output, the average dairy farm had GHG emissions of 0.84 kg CO2 equivalent per kg of milk produced. They said that this compared very favourably as against the global average of over 2kg Co2/e, which was reported by Mazzetto et al in an article entitled “Mapping the carbon footprint of milk production from cattle: A systematic review” in the 2022 Journal of Dairy Science.
The advertisers said that sustainability was about more than just the environment, that it must also consider how agriculture and nutrition balanced social, economic and environmental priorities. They said that a sustainable diet was one that had a low environmental impact, contributed to food and nutrition security as well as a healthy life for present and future generations.
By way of further information, the advertisers said that research carried out by Teagasc and Food for Health Ireland concluded that milk produced by Irish grass-fed dairy cows contained more beneficial nutrients than milk from conventional indoor-feeding practices.
They said that they had joined the UN Global Compact , a voluntary initiative to encourage businesses worldwide to adopt sustainable and socially responsible policies, and to report on their implementation. The UN Global Compact was the world’s largest corporate sustainability initiative with over 13,000 members and other stakeholders from over 160 countries. Members of the UN Global Compact are required to align their operations and strategies to support the ten principles of the UN Global Compact with respect to human rights, labour, environment and anti-corruption as well as advancing the UN Goals including the UN Sustainable Development Goals.
Issue 2:
The advertisers said that the vast majority of farms in Ireland were small. They said that over 15,300 farmers took part in the Teagasc survey in 2022 and the average herd was just 93 cows, and that approximately 78% of the farms surveyed were smaller than 100 hectares. They also said that the vast majority of farms were situated in the south of the country which was a predominantly traditional dairy farming area.
They said that there are over 16,000 farmers, 99% of whom were members of their sustainable dairy assurance scheme and that the carbon footprint from Sustainable Dairy Assurance Scheme members had fallen by 9%, with the average carbon footprint of a certified dairy member being 0.91 kg CO2eq/kg for fat and protein corrected milk.
Conclusion
Complaints Upheld In Part
The Complaints Committee considered the detail of the complaint and the advertisers’ response.
Issue 1 – Upheld:
The Committee noted that the wording used in the Tweet to describe Irish dairy stated “It’s sustainable, natural and nutritious…” and the voiceover in the video accompanying the Tweet described it as “more sustainable, more natural and nutritious..”. The Committee also noted the commentary that the Tweet had included a link to their website where context was provided and that both the Tweet and website should be considered as a whole and in context.
The Committee noted that the complainants had objected to the claim on environmental grounds, while the Committee also noted that sustainability involved more than just environmental issues .
In this case, while the Committee noted the steps taken by Irish dairy farmers to be more sustainable, the wording of the Tweet had included an absolute claim to be ‘sustainable’ without a qualification or evidence to show that it was “sustainable”. In addition, the qualified claim in the video ‘more sustainable’ did not include a comparator for context as to what the benchmark was.
In the circumstances, the Committee considered that references to ‘sustainable’ without a qualification and without a comparator benchmark where appropriate, 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 – Not Upheld:
The Committee noted the complainants considered the claim that Irish dairy was produced in a traditional way was misleading given they believed that large scale farming was carried out in Ireland. The Committee also noted the information provided on the herd and farm sizes in Ireland which showed that a significant number of farms in Ireland were both small in land and herd size and also that dairy farming in Ireland was primarily grass-fed, outdoor based which was a traditional farming method. In the light of this, the Committee did not consider that the claim that dairy farming was produced in a ‘traditional’ way was in breach of the Code.
