In July 2024, the UK’s Advertising Standards Authority (Below we refer to it as the ASA) published “Environmental claims in food advertising,” which provides advice on making environmental claims on meat, dairy, and plant-based food labeling. The following is a brief overview of the advice.

A recent consumer survey conducted by ASA on environmental claims aimed at meat, dairy, and plant-based foods showed that the use of certain “green” or “natural” terms or visual images in an advertising context can create a series of associations and evoke strong speculation about environmental/animal welfare or health benefits of a brand or product. In response to the findings, ASA announced that care should be taken to ensure that such storytelling do not go so far as to foster a misleading disconnect between a particular depiction and reality.

Specifically, it stated that when environmental claims are made using photographs, they should be taken or filmed in the real-world environments which they are depicting, and where this is not feasible, particular care should be taken to avoid exaggerating the nature (visual or linguistic) of real-world agricultural and livestock practices and conditions in a way that goes beyond legitimate storytelling of the products. For example, if your product does not actually relate to “free range” livestock, you need to be careful not to imply this as if it were the case. Finally, the ASA concluded that, as with all advertising, evidence must be held for all environmental claims, whether direct or implied, written or visual.

What about Japan and other countries?

In relation to such environmental claims, the Ministry of the Environment of Japan has established a guideline: “Environmental Labeling Guidelines” (Japanese). The Guidelines states that appropriate environmental labeling must meet the following requirements: the information must be accurate and based on evidence, it must not mislead consumers, the content of the environmental claim must be verifiable, and it must not be ambiguous or abstract.

In addition, the Federal Trade Commission (FTC)’s Environmental Claims: Summary of the Green Guides and the European Commission (EC)’s Products – labelling rules and requirements have also established guidelines and regulations for environmental claims.

Meanwhile in Asia, the Korea Fair Trade Commission (KFTC) has amended its Guidelines for Review of Environment-Related Labeling and Advertising in South Korea. This has strengthened regulations against so-called “greenwashing,” which is the practice of giving the appearance of being environmentally conscious when in fact it is not, and appears to be a trend against environmental claims. As interest in environmental issues continues to grow, the trend to actively incorporate this environmental claim is likely to accelerate. We hope that you will find this information useful when you are planning to make such labeling in accordance with the relevant regulations of each of our target countries.

Akihito Kameyama

Label bank Co., Ltd. Regulatory inspections and Consulting Research staff
Born in Japan. With many years of experience in the additives (formulation) business, his work focuses on additives verification, as well as ensuring the consistency between the technical information in English and Japanese. He also acts as a seminar lecturer on topics related to the standards of use of ingredients.

[Lecture/Seminar]

• “Regulatory Requirements of Food Ingredients/Additives Used in Japan” (ChemLinked: REACH24H Consulting Group/Webinar) Oct. 2020