Letter to the Advertising Standards Authority
The Advertising Standards Authority
Complaints Dept
2 Torrington Place
London
WC1E 7HW
Dear Sir/ Madam
We write to make a complaint against the Soil Associations
leaflet 5 reasons to eat organic, (see attached). This was being distributed
from a Soil Association stand at the Harvest Festival in Ely Cathedral, 10 October 1999.
The leaflet makes 5 claims which we have detailed below with our
reasons for disputing them.
SOIL ASSOCIATION CLAIMS
5 reasons to eat organic:
"You can taste the difference"
"Its healthy"
"Its better for the environment"
"Its GMO free"
"Organic means healthy happy animals"
While it may be possible for each of these claims to argue that they do
apply to some organic farms and produce, it is wrong to imply that all
organic farms comply or that these properties are unique to organic farming.
Organic farming principles may well have positive effects on people,
the environment and livestock. But such benefits are almost impossible to quantify.
In many cases, the philosophy is not yet matched by current knowledge [1] and until
they are claims such as those made by the Soil Association are ill-informed and misleading
to the consumer.
Summarised below is scientific evidence which does not support the Soil
Associations claims. According to The British Codes of Advertising and Sales
Promotion we believe the whole advertisement contravenes the following sections of
the code;
2.1 all advertisements should be legal, decent and truthful.
3.2 if there is a significant division of informed opinion about any claims made in an
advertisement they should not be portrayed as universally agreed.
6.1 advertisers should not exploit the credulity, lack of knowledge or inexperience of
consumers.
7.1 no advertisement should mislead by inaccuracy, ambiguity, exaggeration, omission or
otherwise,
8.1 advertisers may give a view about any matter, including the qualities or desirability
of their products, provided it is clear that they are expressing their own opinion rather
than stating a fact.
19.2 comparisons should be clear and fair. The elements of any comparison should not be
selected in a way that gives the advertisers an artificial advantage.
and the claim "Its better for the environment"
contravenes;
49.1 The basis of any claim should be explained clearly and should
be qualified where necessary. Unqualified claims can mislead if they omit significant
information
49.3 Where there is a significant division of scientific opinion or where evidence is
inconclusive this should be reflected in any statements made in the advertisement.
Advertisers should not suggest that their claims command universal acceptance if it is not
the case.
Claim 1 - "You can taste the difference"
Claim 1 - "You can taste the difference"
a) The statement does not apply to all organic produce:-
The results in the scientific literature show no consistent
pattern for sensory quality between organically and conventionally grown produce.
[3]
In the US the USDA has labelling requirements which prevent producers
making claims that organic foods are better or even different to conventional foods. [6]
In the early 1990s Israeli researchers made 460 assessments
of 9 different fruits and vegetables and no significant difference in quality between
organic and conventionally grown samples. [6]
As part of a survey by the University of California on the differences
between organic and conventionally grown tomatoes, researchers picked 40 people to
do a taste test. Ten people said that the organic tomatoes had better flavour and texture,
ten people said that the conventionally grown tomatoes were better and twenty people could
not tell the difference. cited in [9]
b) The statement is not unique to organic produce:-
They [organic] may be superior to the extent that they may be
fresher: organically grown foods are usually harvested closer to peak maturity and sold
locally, while commercially grown produce is often shipped many miles and may reach the
consumer weeks after harvest [3] This indicates the freshness dictates the taste
rather than the method of production (organic/ conventional). In meat, taste and eating
quality is predominantly affected by the breed of animal, the way it is reared and the way
the meat is treated after slaughter.
Claim 2 - "Its healthy"
a) The statement does not apply to all organic produce:-
In October of 1992, public health officials investigated several
cases of bloody diarrhoea in a small town in Maine; one of the patients...died of kidney
failure. The cause? Escherichia coli 0157:H7, better known as plain E. Coli... the source
of the E. Coli was a fresh vegetable from an organic garden. 3 other separate cases were
traced to organic lettuces, probably contaminated by E. Coli infected cow manure. In the
US over 100 million tons of manure are produced per year and less than 7% is
composted. [4]
A study at the University of Illinois has shown that consumers
eating organic produce are eight times more likely to contract E. Coli [11]
Without fungicides to prevent infection, plants respond by
producing toxins of their own [11]
b) The statement is not unique to organic produce:-
At a conference organised by the Institute of Grocery Distribution on 2
November 1999, four speakers all confirmed, in a variety of statements, that there is no
evidence that organic produce is healthier than conventional. The speakers were:
Elliot Morely MP - Minister of State, MAFF
Andrew Sellick - Development Manager, Tesco
Alan Wilson - Agronomist, Waitrose
Patrick Holden - Director, Soil Association
The claims for better food safety cannot be proved... However,
even where the benefits are real, it appears that most could be achieved by conventional
farms, mainly by changes in management. [1]
There is no conclusive evidence that organically produced food is
safer or less safe than that produced conventionally. [1]
Although there is some evidence of differences between organic
and conventionally produced foods, there is not a great deal of evidence that these
differences represent differences in food quality....The significance of any such
differences for health depends upon the proportion of the diet derived from the particular
product and, indeed, the other constituents of the diet. [1]
There is no evidence whatever to indicate that chemically
fertilised plants are less nutritious than non-fertilised. Director W. M. Fifield of the
Florida Experiment Station has said: Not a single instance has been called to our
attention where the use of chemicals in production or protection of our states crops
or livestock has resulted in harmful effects on humans who have consumed them.
[5]
Organic foods are certainly not more nutritious. Experiments
conducted for many years have found no difference in the nutrient content of organically
grown crops and those grown under standard agricultural conditions. [6]
There is no scientific evidence at this time to suggest that
organically produced foods are more nutritious [8]
Jeanne Goldberg PhD, RD, an associate professor and director of the
Center on Nutrition Communication at Tufts University in Medford, Massachusetts says
Nutritionally speaking, there is absolutely no evidence that organic is better,
youre not going to get any more vitamins and minerals in a peach or strawberry grown
with manure than you will in one grown with commercial fertilisers [10]
In the view of the British Nutrition Foundation, the nutritional
value of organic crops is likely to be the same as that of conventionally grown
crops. [1]
Claim 3 - "Its better for the environment"
a) The statement does not apply to all organic produce:-
The BTO (British Trust for Ornithology) amongst their evidence given to
the House of Lords, noted that some aspects of organic farming may not be beneficial
to bird populations, for example disturbance caused by mechanical weeding, and the early
cutting of clover-based leys. [1]
The use of farmyard manure adds humus to the soil, which aids
structure, and encourages earthworms and other minor invertebrates. It may also add an
excess of phosphates which, although essential plant nutrients, can also cause pollution
of water courses. By contrast, some concern was expressed that phosphorus might be being
removed at a greater rate than it is replaced in organic systems. [1]
If very large organic farms were to become common, it would
remain to be seen whether they brought the same benefits for biodiversity as smaller
organic units. [1]
(In Korea and Japan) The overuse of organic fertiliser by some
organic farmers have caused some severe problems since they apply too much organic
fertiliser compared to the need of crops. This could lead to a potential risk
for NO3- leaching [2]
The use of Red Clover or other leguminous crops to increase soil
nitrogen has been shown to seriously increase nitrogenous pollution of water courses from
field run-off in New Zealand.
b) The statement is not unique to organic produce:-
The Institute of Arable Crops Research (IACR) at Rothamsted said that
any farming system, whether it be conventional, integrated or organic, can achieve
the environmental benefits that organic farming aims to achieve. [1]
Claim 4 - "Its GMO free"
a) The statement does not apply to all organic produce:-
The IACR stated that there is now so much air pollution and such
a widespread distribution of pollutants throughout the whole globe that it is very
difficult to grow an organic crop without some residue of something from somewhere in the
world being deposited on it. [1]
The John Innes Centre stated that there was a need to establish
acceptable levels of the presence of GM material in organic crops. [1]
The feed used in organic farming does not currently have to be 100%
organic. Until 2005 the diet of organic herbivores may be 10% conventional feed, or
20% for other species. [12] Therefore it is impossible to rule out the inclusion of
GMO ingredients in the feed of organic livestock.
b) The statement is not unique to organic produce:-
Under current EU and UK Governmental regulations NO GM crops may be
grown in the UK. Furthermore, an increasing number of supermarkets and other retailers are
excluding GM ingredients from all their produce, not just organic.
Claim 5 - "Organic means healthy happy animals"
a) The statement does not apply to all organic produce:-
Evidence for increased disease resistance, productivity, or
fertility of animals feeding on organically grown fodder is largely anecdotal. [3]
Animal health control methods used in organic farming guarantee similar,
and occasionally better, animal health situations on organic farms in comparison
with conventionally managed farms. [1]
Some of the standards set down for the management of animal
health, while the motives may be well intended, could in fact jeopardise the health and
welfare of animals or put human health at risk. [7] Restrictions on the use of
medicines raises animal welfare concerns.
Certain organic farming principles could act contrary to the needs of
the animal.
- Certain animal medicines, approved under EU and UK law, are prohibited, limiting the
range of products available to treat animal, (e.g. all forms of organophosphate products,
all medicines derived from genetic engineering).
- Organic principles impose an automatic doubling of the statutory withdrawal
period, determined under EU law, (the period between final treatment and slaughter,
or eggs, milk etc for human consumption). This rule means that if animals fall sick
shortly before slaughter (etc.) the farmer/ vet must either decide not to treat, or face
financial loss.
- Contrary to the concept that Prevention is better than cure, organic
principles strongly discourage preventative medicine, even vaccination, other than when
diseases is endemic. This means that an animal must first fall sick (and suffer) while
developing symptoms sufficient to justify treatment.
- Organic farming tends to be synonymous with free range production. Free
range production inevitably exposes animals to the elements, all the year round, and to
disease carried by wild animals and birds.
b) The statement is not unique to organic produce:-
Animal welfare is principally the result of housing and management.
Although organic farming forbids certain practices such as battery cages, we are unaware
of any housing or management practices which are unique to organic farming.
While it may be possible for each of these claims to argue that they
do apply to some organic farms and produce, it is wrong to imply that all
organic farms comply or that these properties are unique to organic farming.
As this is the first complaint we have made to the ASA, there may
be errors in the format of this submission, or further information you require - if so do
please contact us and we will be pleased to comply.
Yours faithfully
Roger R Cook (Mr)
DIRECTOR
References:
1. House of Lords European Communities Sixteenth Report 20 July 1999
2. Sohn, S.M. (1996) Nitrate and Overuse of Organic Fertiliser S1,
IFOAM Book of Abstracts [Online] http://www.ecoweb.dk/english/ifoam/conf96/abs034.htm
3. Finesilver, T, Johns, T and Hill S.B. (date unknown) Comparison of
Food Quality of Organically Versus Conventionally Grown Plant Foods, Ecological
Agriculture Projects [Online] http://eap.mcgill.ca/Publications/EAP38.htm
4. Nelson, H. (Date unknown) The contamination of Organic Produce by
Human Pathogens in Animal Manures, Ecological Agriculture Projects [Online]
http://eap.mcgill.ca/SFMC_1.htm
5. Throckmorton, R.I. (Date unknown) The Organic Farming Myth, Kansas
State College, [Online] http://eap.mcgill.ca/Indices/Organic_agriculture/OAM.htm
6. Barrett, S. (Date unknown) Organic Foods: Will Certification Protect
Consumers? [Online] http://www.quackwatch.com/01QuackeryRelatedTopics/organic.html
7. NOAH (1990) Position Paper on Organic Farming
8. Organic Trade Association (Date unknown) Frequently Asked Questions:
Is Organic Food Better for You? [Online] http://www.pavich.co/organicissues/faqs.htm
9. Mael, S (1997) Agroecology Group Project, Organic Farming [Online]
http://w3.uwyo.edu/~pz/pz2.html
10. Holman, J.R. (Date unknown) Phys. Trick or Treat? What Organic
Really Means, [Online] http://www.phys.com/d_magazines/01self/organic/organic.html
11. Trewavas, T. (1999) Organic Safety Scare, BAA Grapevine
12. Farm & Country Retailer (1999) EU Regulates Organic Livestock,
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