National Office of Animal Health

...for the welfare of all animals

HOME | NEWS | MEDICINES TOPICS | ABOUT NOAH | BOOKS | CODE | LINKS | CONTACT | JOBS | COMPENDIUM

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 Association’s 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"
"It’s healthy"
"It’s better for the environment"
"It’s 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 "It’s 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 1990’s 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 - "It’s 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 state’s 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, you’re 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 - "It’s 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 - "It’s 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.

  1. 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).
  2. 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.
  3. 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.
  4. 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, Nov-Dec, p.6