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ESG Enforcement Tracker

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ASA upholds in part complaint against “Let’s Eat Balanced” campaign

Date:
13 May 2026
Relevant legislation/regulation:
UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) (edition 12), rules 3.1, 3.3 (Misleading advertising) and 3.7 (Substantiation) and 11.3 and 11.4 (Environmental claims) and Consumer Protection from Unfair Trading Regulations 2008
Jurisdiction:
United Kingdom
Status:
New, Closed
Regulator/enforcement authority:
Advertising Standards Authority (ASA)
ESG Category:
Environmental
Defendant(s)/subjects(s):
Agriculture and Horticulture Development Board

Key Facts:

The ASA has upheld in part a complaint against the Agriculture and Horticulture Development Board’s (AHDB) “Let’s Eat Balanced” campaign, finding that some of its advertisements featured misleading environmental claims.

The campaign included two national press advertisements for British beef and milk. One featured the claim that British beef “has a carbon footprint that’s half the global average” with an asterisk linking to text stating “Full lifecycle emissions of CO₂ eq [carbon dioxide equivalent] per kg of beef”. The other stated that British milk “has a carbon footprint a third lower than the global average” with the footnote “Full lifecycle emissions of CO₂ eq [carbon dioxide equivalent] per kg of milk”.

The relevant CAP code states that advertisers must base environmental claims on the advertised product’s full lifecycle, unless the advertisement states otherwise, and that the limits of the lifecycle must be clear. In this case, the ASA concluded that the evidence that ADHB had relied upon to substantiate the claims did not include the full lifecycle of the products up to disposal, but that the average consumer was likely to understand the advertisement in that way. Consequently, it held that these advertisements breached the CAP code provisions on misleading advertising, substantiation and environmental claims.  It rejected all other challenges to the “Let’s Eat Balanced” campaign advertisements.

The ASA carried out its assessment of the claims using the version of the CAP code in force before the amendments introduced by the Unfair Commercial Practices provisions in the Digital Markets, Competition and Consumers Act 2024 (DMCCA) in April 2025. 

Sources: 

ASA press release

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