The banner advert, which featured on Tesco’s online store, and previously received complaints when it featured on London's Underground, contained an image of two cows. A speech bubble from one of the animals reads: "This latest high-protein diet is amazing, hun. You must try it." To which the second replies: "No thanks, love, I'm organic. I only do natural." The text underneath the image the states: "Organic. Naturally different.”
The complainant said the advert suggested high-protein dairy cow diets were not natural and that no cows from which organic milk was sourced were fed high-protein diets. The agency sought advice from the Organic Trade Board and Dairy Co, which led it to conclude that it was reasonable to assert dairy from cows fed on a high-protein diet was not natural, and that the advertisement's presentation of this was not misleading.
High protein diet
The Organic Trade Board, which produced the advert, responded to the criticism saying a dairy cow's diet influences milk yield, higher yields requiring higher protein intake. It said the emphasis in conventional, non-organic dairy farming was on the feeding of chemically altered or genetically modified feed ingredients to increase protein and energy concentration in the diet, with the aim of increasing milk yield at a lower cost of production.
It said non-organic cows could not achieve current levels of milk production purely on grass pastures or forage alone since protein levels were lower in forage than in concentrate animal feed.
In its conclusions, ASA said: “We understood that dairy cows were routinely fed a combination of forage and concentrate, and that the concentrate element of the diet was generally higher in protein; where a farmer wished to increase the protein content of their herd's diet (often for the purposes of increasing yield), they would typically increase the proportion of concentrate in the diet.”
Naturally ‘natural’
With regards to the complaints surrounding the use of the term 'natural', the Organic Trade Board said it was in keeping with the Food Standards Agency’s (FSA) definition. It said this asserted that a 'natural' food for humans comprises of ingredients produced by nature, without interference from man, chemicals or technology. ASA said that FSA applied a “slightly different meaning” to the word ‘natural’ than that featured in the advert, but said in the absence of clarification consumers were likely to interpret the use of concentrate feed, in both non-organic and organic cow diets, to disqualify the description 'natural', regardless of whether that diet was high in protein.
Included in ASA’s evaluation, the Organic Trade Board suggested that while the content of organic cow diets was strictly regulated by EU law, non-organic dairy cow diets "frequently included" the use of GM ingredients and feeds which had been chemically treated or altered, such as soya oil extracted using chemical solvents and urea-treated wholecrop, and were therefore "not natural".
ASA concluded: “We considered that consumers were likely to understand from [the advert text] that high-protein dairy cow diets were not natural.”
“We considered that most consumers would understand from the ad that, whereas some conventionally managed cattle were fed diets artificially high in protein, organic dairy farming precluded such a practice,” it said.