Who: The Advertising Standards Authority (ASA) and the Agricultural and Horticultural Development Board (AHDB)
Where: United Kingdom
When: 13 May 2026
Law stated as at: 12 June 2026 (Note: This ruling was decided based on the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code) as existed prior to 6 April 2025)
What happened:
The AHDB, a non-departmental public body and levy board that supports British farming, ran a series of advertisements promoting British-farmed produce. This included three TV ads promoting the nutritional value of British dairy, beef and lamb using the slogan “let’s eat balanced” (LEB) and showing images of green pastures. Additionally, there was an LEB webpage and social media post similarly highlighting the nutritional value, quality and good farming practices behind British produce. Finally, national press ads for British beef and dairy claimed that these products have, respectively, a carbon footprint that is half the global average and a third lower than the global average.
The ads were challenged on whether: first, all of the ads were misleading as to the full environmental impact of British meat and dairy; second, the carbon footprint claims in the national press ads were misleading and could be substantiated; and third, the ads were misleading in suggesting that cows used to produce beef and milk in the UK were typically outdoor grazed.
Environmentally misleading
The ASA concluded that the ads did not make misleading environmental claims.
On the TV ads, the ASA considered that the overall impression of each ad was that the products advertised were typically produced within the UK and had various nutritional benefits, which contributed to a balanced diet. Consumers were likely to understand the imagery of grassy fields and pastures in that context as a generic indication that the foods were typically sourced from the natural environment associated with rural areas in the UK and derived benefits from that environment. The ads therefore related to the provenance and nutritional properties of British livestock, not environmental benefit.
The ASA also found that information in a website ad demonstrated to the average consumer the high quality standards of British farming instead of making any claims as to environmental benefit. The reference to “environmental care” in the ad’s context was likely to be understood as meaning standards were in place to mitigate some of the environmental impacts of farming practices. The ad made no guarantees about the extent of the care.
A quote from an individual farmer about “looking after our Great British countryside” in a social media ad was held to be reflective of individual business practices and a possible vision of future farming. The ASA therefore considered that the basis of the claims was clear, and consumers were unlikely to interpret the ad as suggesting that the practices referred to were currently reflective of British livestock farming’s overall environmental impact. The press ads relating to carbon footprint highlighted an environmental benefit, it was made in the specific context of a comparison of British produce against the global average. The ad did acknowledge that the products cause environmental harm. The ads therefore did not make a wider claim about environmental benefit.
Carbon footprint
Under the CAP Code, marketers must base environmental claims on an advertised product’s full life cycle (unless the ad stated otherwise), make clear the limits of that life cycle and ensure that claims based on only part of the life cycle do not mislead consumers as to the product’s total environmental impact. Where a general environmental claim cannot be justified, marketers may instead make a more limited claim relating to specific aspects of the product.
The national press ads containing carbon footprint claims also included footnotes which stated: “Full lifecycle emissions of CO2 eq per kg of beef/milk”. The AHDB claimed that the average consumer would interpret the full life-cycle of a product as meaning from the “cradle to retail” stage, from the extraction of resources to produce inputs for agricultural production to the retail store, excluding consumption and disposal. The ASA disagreed, considering that consumers would view the claims as extending beyond the retail stage, such as cooking and wastage.
The ASA therefore found that the evidence provided by the AHDB was insufficient to support the full life cycle claims (as interpreted by the AHDB) and that the ad was misleading.
Outside grazing
The ASA found that the ads depicting grassy fields and cows grazing outside would be interpreted by consumers as illustrating how some cows were farmed in the UK and the benefits of this, rather than as a claim that all UK cows were kept outside at all times. Research reviewed by the ASA also demonstrated that most British cattle had access to an outdoor environment.
The ASA therefore found that the ads’ imagery was not misleading.
Why this matters:
This ruling has significance for advertisers making environmental claims, especially those concerning carbon footprint, as it clarifies the definition of an advertised product’s full life cycle to extend beyond the retail stage to include wastage. Furthermore, advertisers should take care when substantiating such claims to ensure they have sufficient evidence.
Goldia Kuok, trainee solicitor with Osborne Clarke, contributed to this article.
