Background
Summary of Council decision:
Four issues were investigated, all of which were Upheld.
Ad description
Two posts for dogfood company Wild Pack, on their Instagram page jointhewildpack, seen in October 2024:
a. The post featured a video of Geogia Toffolo, the owner of Wild Pack. The video began with Ms Toffolo stating, “Let me tell you a tale of canines, kibble and corruption”, as images of dogs, dog food and money appeared on-screen. She continued, “I discovered an industry rotten to the core when I entered the shadowy world of dog food. Where a thinly veiled cartel used their position of power to drown out the voice of over 40,000 dog lovers […] Here’s what the UK petfood industry doesn’t want you to know”, before explaining how she applied for Wild Pack to join UK Pet Food, the trade association for pet food manufacturers and suppliers, but her application was rejected. She said this was because she had recently launched a campaign to ban glycotoxins in dog food, which were “harmful chemicals that lead to cancer, diabetes, kidney failure in ultra processed kibble”. The video showed a clip of Ms Toffolo on a call with UK Pet Food in which she was told that “the executive committee say that would be breaking our code of conduct”.
She said, “UK pet food is funded by member fees, with the largest companies paying up to £2 million each year. And who are the largest most influential members? Surprise, surprise – it’s these guys.” The brand logos of Nestle Purina, Mars Incorporated and Colgate-Palmolive appeared on-screen. She said, “From now on I will refer to them only as The Kibble Cartel” as an image of a well-known known drug lord, the text “TH£ KIBBL£ CART£L” and the same brand logos used previously appeared on-screen.
She continued, “The Kibble Cartel controls the whole supply chain, from production to regulation. And what’s worse is the sheer number of vets on the payroll of these huge companies. Some vets are said to be paid up to £30,000 to promote kibble. So next time you get nutrition advice from your vet, check first if they are on the cartel’s payroll,” She described “The Kibble Cartel” as the “judge, jury and executioner” and concluded that “they want you to believe they protect your pet’s safety. But in reality, they safeguard large-scale corporate profit. We can’t let this happen.”
The post’s caption included similar claims.
b. The second post opened with a clip of Georgia Toffolo talking about “The Kibble Cartel”. She stated that “The Kibble Cartel love to tell you big lies on their packaging. Just have a look at this Bakers product from Purina”. An image of one of their products appeared on-screen. She talked about claims stated on the packaging: “This says 100% tender chunks. It says beef in big capital letters. But have a closer look at the ingredients on the back.” An image of the ingredients list appeared on-screen as she stated “This product is actually less than 1% beef. It also says it’s made with country vegetables. Actually, no, it’s another lie. It’s actually made with derivatives of vegetable origin. This means it’s actually just a bulking agent […]”.
She then showed a Beta product from Purina. She said, “It says ‘Made with natural ingredients’. ‘Chicken number one ingredient’. These are yet more misleading labels as this is only 28% chicken meal” and that chicken meal “[…] can legally be made from animals which are already dead, dying or diseased.” A video of what appeared to be a meat factory appeared in the background.
The caption included the following text: “The Kibble Cartel can be very creative with their language. Whether they’re referring to powdered carcasses as ‘beef’ or UHT bulking agents as ‘country vegetables’, they’re pretty liberal with their terminology.”
Issue
The complainant, a canine nutritionist, challenged whether the following claims were misleading and could be substantiated:
- in ad (a), that “[…] vets are said to be paid up to £30,000 to promote kibble”, in reference to UK Pet Food members;
- in ad (a), that glycotoxins in “ultra processed” kibble “lead to cancer, diabetes, kidney failure”; and
- in ad (b), that “chicken meal can legally be made from animals which are already dying, dead or diseased”.
- They also challenged whether ads (a) and (b) discredited or denigrated UK Pet Food, Nestle Purina, Mars Incorporated and Colgate-Palmolive.
Response
- Montdog Ltd t/a Wildpack said that the claim that “[…] vets are said to be paid up to £30,000 to promote kibble” was based on anecdotal evidence gathered from interviews with individuals who had worked in veterinary practices. These sources requested anonymity and could not provide documented evidence to substantiate the claim publicly. They further explained that the veterinary profession was bound by confidentiality and involved significant professional risks. These individuals were not merely “anecdotal” but real individuals with first-hand experience.
- Wildpack provided an abstract from a PhD thesis, a published literature review, a published study, and the abstracts of two published research papers to support their claim about glycotoxins and their link to chronic diseases. They further stated that there was a growing, widely accepted scientific consensus regarding the dangers of ultra-processed foods in human nutrition. They said that suggesting similar risks could not reasonably be extended to pets, especially given their smaller size and limited diets, was an outdated perspective. They emphasised that their content reflected both advancing research and mounting public concern.
- Wildpack said that their statement that “chicken meal can legally be made from animals which are already dying, dead or diseased” was based on information from US practices. They said that the product mentioned, as a global corporation, had overseas practices relevant to UK consumers, much like in other industries such as fashion, food and technology. They stated that ethics transcended borders and that exposing a company’s known practices abroad was a vital aspect of consumer advocacy.
- Wildpack said that their references to UK Pet Food and certain large pet-food companies, including terms such as “Kibble Cartel,” imagery of Pablo Escobar, and suggestions of secrecy or corruption, were intended as a humorous comparison to highlight market dominance, not a literal allegation of criminality. They further stated their tone was purposefully bold to emphasise the gravity of the issue. They said that the term “cartel” was commonly used to describe concentrated corporate power.
Assessment
1. Upheld
The ASA considered consumers would interpret the claim in ad (a), stating “[…] vets are said to be paid up to £30,000 to promote kibble”, as suggesting that members of the trade body UK Pet Food were financially incentivising vets to recommend certain pet food brands. Ms Toffolo further advised consumers “next time you get nutrition advice from your vet, check first if they are on the cartel’s payroll” which we considered reinforced that impression. However, the advertiser provided no evidence to support the claim. We therefore concluded that the claim had not been substantiated and was therefore misleading.
On that point, ad (a) breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation).
2. Upheld
Ad (a) featured the claim that glycotoxins in “ultra processed” kibble “lead to cancer, diabetes, kidney failure”. We considered consumers would understand the claim to mean that kibble (dry dogfood) contained levels of glycotoxins that posed significant health risks to dogs, potentially leading to chronic diseases such as cancer, diabetes and kidney failure. Additionally, we considered it would encourage dog owners to seek alternative foods.
We assessed the evidence provided by Wildpack. The first document was an abstract from a PhD thesis. We were not provided with a full copy of the paper or a published version and considered that abstracts alone were not adequate substantiation for advertising claims. In any case, we understood the paper evaluated how differently processed diets influenced the faecal microbiota in healthy dogs, but did not investigate the possible negative impacts on health. We therefore understood the full paper also would not have been adequate to support the claim.
The second document was a literature review, published in a peer-reviewed journal. It evaluated the effect on nutritive value and pet health caused by the ‘Maillard reaction’ in pet food processing. The Maillard reaction was a chemical reaction that could occur in foods cooked at high temperatures, which reduced the bioavailability of amino acids. The paper concluded that significant proportions of the amino acid lysine in pet foods could be modified by the reaction and may be unavailable for metabolism by dogs and cats. However, it also concluded that further study was needed to determine if this could lead to diseases such as diabetes and impaired renal function in pets.
The study, published in a peer-reviewed journal, examined the correlation between dietary intake of Advanced Glycation End Products (AGEs) and their urinary excretion in dogs and cats. Data was collected in relation to a group of dogs fed raw food, and a group fed dry processed food, using spot urine sampling and questionnaires. The study concluded that dogs primarily fed raw food with a low intake of dietary AGEs had significantly lower concentrations of free-form AGEs in their urine compared to those fed processed food. However, the study did not investigate the effects of these dietary differences on pet health.
Regarding the two further abstracts from published research papers, one paper suggested a possible role of AGEs in the development of canine atherosclerosis (a condition where the arteries became narrowed and hardened due to the build-up of plaque on the artery walls) in three dogs. The second paper examined the AGE distribution in the cerebellum and brainstem of 18 dogs. Because full studies were not submitted, and the sample sizes used or referred to were too small for results to be extrapolated to the wider population, we considered that they did not constitute adequate substantiation for the advertising claim.
We considered that while some of the evidence indicated that some levels of glycotoxins were present in “ultra processed” kibble, they did not indicate that they posed significant health risks to dogs, including that they could “lead to cancer, diabetes, kidney failure”. We concluded that the claims had not been substantiated and were therefore misleading.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation).
3. Upheld
We considered that consumers would interpret the claim “chicken meal can legally be made from animals which are already dying, dead, or diseased” in reference to a Purina product, to mean that specific product contained chicken meal made from dead, dying and diseased animals. We further considered they would understand it more generally to imply that ingredients in most pet foods in the UK were of lower quality and potentially harmful to their pets' health. This impression was further reinforced by the inclusion of a video depicting what appeared to be a meat factory in the background as Ms Toffolo made this claim.
The advertiser did not provide any evidence to substantiate the claim, either specifically in relation to the named Purina product or more generally to pet foods in the UK. While we acknowledged Wildpack's comment about the relevance of overseas practices to the UK, we noted that they were a UK based business selling to customers in the UK, with their ads directed at a UK audience. The claims in question focused on two products sold within the UK, which viewers of the videos would have reasonably understood to relate specifically to UK practices. Consequently, it was necessary to substantiate these claims with evidence relevant to the UK. Therefore, we concluded the claim “chicken meal can legally be made from animals which are already dying, dead, or diseased” in ad (b) had not been substantiated and was misleading.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation).
4. Upheld
The CAP Code stated that marketing communications must not discredit or denigrate another product or marketer. The rule applied irrespective of whether or not a claim was true, if it appeared in a comparative advertisement and was expressed in terms which were insulting, derogatory or demeaning. Ads which included comparisons with competitors which went beyond a robust and objective comparison of their products or services risked breaching that rule.
In ad (a), Ms Toffolo characterised the UK pet food industry as “corrupt”, a “shadowy world” and “rotten to the core.” She described UK Pet Food as a “thinly veiled cartel” and “the judge, jury, and executioner”, and specifically highlighted that its member companies included Nestlé Purina, Mars Incorporated, and Colgate-Palmolive. The ad repeatedly referred to them collectively as the “Kibble Cartel,” and emphasised this depiction of them by displaying an image of the drug cartel leader Pablo Escobar. It suggested that these entities prioritised corporate profitability over the safety of pets, including by paying vets to promote products which were implied to be nutritionally inadequate, and that they used their position of power to “drown out the voice of over 40,000 dog lovers”.
Ad (b) also referred to UK Pet Food and its members as “The Kibble Cartel”. It was also stated that the “Kibble Cartel” told “lies” and included “misleading labels” on their packaging.
We considered that ads (a) and (b) went beyond objective comparison, instead criticising UK Pet Food and its members in a way that suggested they were secretive, corrupt, dishonest and engaging in illegal behaviour. We concluded that the ads denigrated UK Pet Food, Nestlé Purina, Mars Incorporated and Colgate-Palmolive, and therefore breached the Code.
On that point, ads (a) and (b) breached CAP Code (Edition 12) rules 3.35 (Comparisons with Identifiable Competitors) and 3.42 (Imitation and Denigration).
Action
The ads must not appear again in the form complained about. We told Montdog Ltd t/a Wildpack to ensure their future ads did not claim that other pet food products posed significant health risks or led to chronic diseases unless they held adequate substantiation. We also told them not to claim that vets were paid to promote dog food by UK Pet Food or its members, unless they held adequate substantiation. We told them not to make claims about the provenance of ingredients in other pet food products unless they held adequate substantiation. We further told them to ensure their ads did not discredit or denigrate UK Pet Food, Nestle Purina, Mars Incorporated, Colgate-Palmolive or their other competitors’ products.
