When it comes to 'greenwashing', the organic sector is one of the major culprits, so it is perhaps the ultimate irony that the EU's proposed Green Claims Directive, designed to prevent consumers being misled about a product's environmental credentials, specifically excludes organic products. Under the new rules, consumers can continue to be duped into paying a premium for organic food, believing they are doing their bit for the environment, when the scientific evidence surrounding the organic sector's green credentials is highly contested, primarily because organic farming consumes much more land and natural resources than equivalent non-organic farming systems to produce the same amount of food. Thankfully, the EU rules will not apply in the UK, where there have been numerous occasions on which the organic sector has been called to account for greenwashing. People should be free to choose organic. But in doing so they should not be misled about its environmental impacts. It is time to adopt consistent, science-based metrics at farm-level to let consumers know how products compare in terms of their impact across a range of sustainability factors, including land and water use, carbon emissions, as well as their effects on soil health, water quality and biodiversity, argue retired UK economist Dr Derrick Wilkinson and SSA co-ordinator Daniel Pearsall. 

  

On 17 June 2024, the EU Council of Ministers adopted its position on the Green Claims Directive, a regulatory proposal first introduced by the European Commission in March 2023 as part of the European Green Deal initiative.  

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​The aim of the new legislation is to tackle 'greenwashing' by regulating environmental claims, ensuring that consumers are not misled into buying products which may appear greener than they really are. 

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The background to the proposal was a 2020 study by the Commission which found that more than half of environmental claims (53.3%) provided vague or misleading information about products' environmental characteristics. The study also analysed the extent to which claims could be backed up with evidence, and found that as many as 40% of claims were unsubstantiated.

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The need for more consistent and objective information about environmental sustainability is particularly evident in the food and drink sector, with supermarket aisles literally awash with products claiming to be more 'natural', 'eco-friendly', 'low-carbon' or 'sustainable'. 

 

Consumers are increasingly alert to the environmental and food security challenges facing the planet, and want to play their part by making more sustainable choices. They understand that the world needs to feed an expanding population, while addressing the challenges of climate change, biodiversity loss and pressure on finite resources of land, energy and water.

 

It is therefore critically important that consumers receive meaningful and evidence-based information about the environmental impact of their food choices. 

 

But in framing this new legislation, the European Commission has made the incomprehensible decision to exempt one of the sectors most frequently associated with greenwashing - organic food and farming. 

 

Article 1(9) of the draft Directive notes that in accordance with the European Green Deal target of achieving 25% of EU agricultural land under organic farming by 2030, and in view of the need to develop organic farming further, "this Directive should not apply to environmental claims on organically certified products," adding that "the positive impacts of organic farming on biodiversity, soil or water" are substantiated by virtue of Regulation (EU) 2018/848 of the European Parliament and of the Council on organic production. 

 

It is the ultimate irony. 

 

In themselves, these statements and the decision to exempt organic farming from the scope of the Green Claims Directive could arguably be construed as greenwashing, since the  scientific evidence surrounding the organic sector's 'positive' environmental impact is highly contested, primarily because organic farming consumes much more land and natural resources than equivalent non-organic farming systems to produce the same amount of food.     

 

In relation to biodiversity, for example, the largest UK study comparing the environmental impacts of organic vs. conventional farming practice, led by the Government's former food security champion Professor Tim Benton, concluded in a 2013 paper in the Journal of Applied Ecology that "the relatively low yields of organic farms may result in larger areas of land being brought into production (locally or elsewhere), at a biodiversity cost much greater than the on-farm benefit of organic practice".      

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Independent research published in Nature has also shown that if England and Wales switched 100% to organic, it would lead to a 21% increase in the greenhouse gas emissions associated with our food supply, primarily because of the greater need for imports caused by a 40% reduction in food production compared to non-organic. 

 

As regards the EU's Green Deal target of 25% organically farmed land by 2030, again the evidence of positive environmental effects is far from conclusive.

 

An impact assessment by Wageningen University, for example, concluded that switch to organic in some crops would be detrimental to the EU's targets for reducing the use and risk of pesticides, mainly due to the organic sector's reliance on using copper-based active ingredients in high volumes to control disease. 

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The same study noted that since EU crop yields under organic systems are up to 47% lower than conventional, increasing the organic area would reduce EU agricultural production, and, as a result, emissions and other negative environmental impacts would be externalised to countries outside the EU due to increased food imports.

 

Despite the scientific evidence to challenge organic farming's green credentials, however, European policymakers seem determined to ensure that the sector enjoys a Teflon-coated protective shield. 

 

Indeed, the EU Green Claims Directive will mean that EU consumers can continue to be duped into paying a premium for organic food, believing that they are doing their bit for the environment. 

 

The EU Green Claims Directive and its exemption for organic food and farming will not, thankfully, apply in the UK, where there have been numerous occasions on which Britain's organic industry has been called to account for greenwashing.

 

In 2017, for example, a complaint against dairy co-operative Arla Foods for advertising its organic milk as "good for the land" and "helping support a more sustainable future" was upheld by the Advertising Standards Authority (ASA) as misleading, because Arla could not provide substantiated evidence that organic milk production has an overall positive effect on the environment.           

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That could, possibly, be because the scientific evidence points in the other direction. Commenting on the findings of a 10-year international study comparing the environmental impacts of different farming systems, led by conservation scientists at the University of Cambridge and published in Nature, Professor Andrew Balmford FRS said:

 

"We found the external harms of high-yielding systems quite often turned out to be much lower than those of more extensive systems, such as organic farming. In terms of nitrogen and phosphate losses from different dairy systems, for example, the difference was a factor of two. So, if you want to reduce pollution, you should probably avoid organic milk."

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Even the organic industry's own trade body has fallen foul of the rules. In 2011, the ASA banned an advert run by the Organic Trade Board (now rebranded as UK Organic) for claiming, without substantiated evidence, that "no system of farming has higher levels of animal welfare than organic farms."

 

Indeed, the ASA now devotes a series of pages on its website specifically to advertising and marketing claims related to organic food and farming, which includes guidance such as:

 

"Unqualified, absolute claims such as "environmentally friendly" or "sustainable" should not be used to describe organic food production because all managed food production systems cause some damage."

 

"...marketers should not claim that organic food is natural, uses only substances that occur in nature, or does not use artificial man-made substances, or any similar absolute terms, if any "approved" substances have, or might have, been used."

 

"Claims that particular substances are not used should not actively disparage non-organic farming or imply that non-organic farming is dangerous."

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Many people might agree that this ASA guidance is brazenly and routinely breached in organic marketing and advertising, whose central objective appears to be to depict organic farming as natural while demonising non-organic farming.

 

Just to illustrate the point, the Soil Association has produced its own guidance document entitled "Marketing Organic: What you can say in marketing and advertising", intended to help industry marketeers avoid ASA complaints and challenges.  

     

Regrettably even this document includes statements which conflict directly with the ASA guidance above, not least: "Organic standards prohibit GM crops and ingredients....all of which have negative health outcomes." 

 

In view of the extensive peer-reviewed and empirical evidence demonstrating the safety of approved GM crops after almost 30 years' widespread cultivation and consumption around the world, the Soil Association must substantiate this damaging claim, or withdraw it. 

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But there's more. Possibly the irony of all ironies. The Soil Association's 'Marketing Organic' guide was removed from its website in may this year when, you guessed it, the document itself was found to contain greenwashing with unfounded and misleading claims relating to the rate of soil erosion across UK farmland. 

 

You really couldn't make it up. 

 

People should be free to choose organic. But in doing so they should not be misled about its environmental impacts. 

 

We have said this before, and we will say it again. 

 

It is time to adopt consistent, science-based metrics at farm-level to inform the policy agenda, to help drive best practice in terms of sustainable, efficient food production, and to let consumers know how different products compare in terms of their impact across a range of sustainability factors, including land and water use, carbon emissions, as well as their effects on soil health, water quality and biodiversity.   

 

It's not rocket science. Let's hope UK Ministers are listening.   

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Dr Derrick Wilkinson is a retired UK economist with nearly 40 years’ international experience with the development, analysis, integration and coordination of global trade, environment and agriculture policies. A former chief economist at both the NFU and CLA, he is the author of numerous pioneering papers and research projects published, including in major peer reviewed journals.

 

Daniel Pearsall is an independent consultant specialising in communication and policy development in the farming, food chain and agri-science sectors. He runs a small livestock farm in Scotland. He co-ordinates the Science for Sustainable Agriculture initiative.