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IAMS policy statement and ASA logoAd watchdog whitewashes Procter & Gamble/IAMS in perverse ruling

After over three years of messing us around, the Advertising Standards Authority (ASA) has rejected a complaint lodged by Uncaged over a confusing and misleading animal testing policy statement issued by Procter & Gamble's pet food subsidiary IAMS. This latest ruling falls into a pattern of ASA bias against animal protection groups and illustrates this industry-funded body's lack of credibility.

We are providing this analysis of the complaint in order that you can judge for yourself.


After Uncaged had publicised scientific papers detailing IAMS' painful and lethal experiments on cats and dogs, IAMS' responded by issuing a cleverly-worded policy statement (PDF) in June 2002 in a desperate effort to improve their public relations. The research policy was vague, equivocal and, we felt, likely to mislead many consumers in the following ways:

  1. IAMS claimed that their experiments would no longer lead to cats and dogs be killed, but an undercover investigation suggested otherwise
  2. The wording of the policy implied that certain aspects of the policy applied to all the animals used in IAMS research, when in fact the whole policy only applied to cats and dogs
  3. IAMS' claim that they would only carry out animal research that was equivalent to studies acceptable in people was patent rubbish
  4. IAMS' claim that they would use animals from the 'general population' (i.e. pets) in their 'studies' (they use the word 'studies' rather than 'experiments' to make their research sound more benign!) was misleading because, as IAMS has quietly admitted elsewhere, they perform laboratory experiments on purpose-bred animals.

We received many emails from members of the public flummoxed by IAMS' statement, and so we contacted IAMS for clarification. IAMS did not reply. The ASA's rules state that an advertiser must have documentary proof to back up their claims.

Here we focus on points 2 and 3, where we believed our complaint was 100% solid, to demonstrate the perverse nature of the ASA's ruling. (Click on point 1 to link to further evidence related to these aspects of the complaint; point 4 is basically covered by point 3 discussed below.)


What IAMS claimed: In some places, IAMS referred specifically to testing on cats and dogs, e.g. they specifically claimed that they would not kill cats and dogs in their experiments. While elsewhere they referred to animals in general: 'We will not use, in any studies, animals that are already induced with disease...' The title of the statement is also very general: 'Research Policy'.

Why we felt it was misleading: It was unclear whether IAMS' stated policy - or parts of it - covered all animals or just cats and dogs. We then received confirmation that IAMS were in fact killing animals apart from cats and dogs in their experiments. Therefore we complained that readers would assume from IAMS' statement that the policy covered their animal experimentation practices in general, not just their treatment of cats and dogs.

We feel that by their ambiguous wording and failure to state in the policy that it only covered cats and dogs, IAMS were trying to give the impression that this was their general approach to animal testing. They were exploiting the fact that most people would be totally unaware that animals apart from cats and dogs would be used in lethal laboratory experiments for pet food! Therefore, they were concealing, by omission, their cruel experiments on animals, which is a breach of the ASA's Codes.

What the ASA have ruled: The ASA seem to have accepted IAMS' nonsensical argument that because the accompanying pictures were of cats and dogs and that the leaflet was about cat and dog nutrition, then readers would infer that the policy referred to cats and dogs only.

Why the ASA are wrong: To us, these factors just compound the deception. One would expect pictures of cats and dogs in relation to studies relevant for cat and dog food. Readers may infer that the policy referred to cats and dogs as the totality of IAMS' animal research, but not cats and dogs only as opposed to other animals who would be used in more severe and lethal experiments! IAMS could have easily made this clear in the statement, but they chose not to. Significantly, many pro-IAMS letters by supermarkets - which we submitted to the ASA - also referred to 'animals' rather than specifying cats and dogs.

The ASA summarily dismissed this evidence and argument.


What IAMS claimed: We were very concerned about IAMS' claim: 'We will only conduct research that is equivalent to nutritional or medical studies acceptable on people'. (Note that again, the term 'research' is used in a general sense, without any clarification about what species it applies to.)

Why we felt it was misleading: This complaint concerns readers' interpretation of the ethical claims made by IAMS regarding their research practices. Therefore, this issue of 'equivalence' with human studies is a question of ethical equivalence. Central to research ethics is the issue of 'consent'. Of course, animals themselves cannot consent to being used in research, which is why the relevant comparison is with humans who cannot give their consent, e.g. infants and those with severe mental impairments. The following passage is from an article published in the Journal of Medical Ethics (Thomas, 2005: 200):

'Animals, of course, cannot give consent. In a therapeutic setting, they rely on their owners to give consent on their behalf. The fact that treatment may be experimental is no bar, provided again that the particular animal may benefit. As with patients lacking capacity, the consent of the animal is, in effect, presumed if the treatment is in it best interests. Animal experiments, by contrast, never benefit the particular animals experimented upon and are not designed to. This is why the correct comparison is with non-consensual experiments on people.'

As Thomas points put later on, examples of non-consensual experiments on people include:

  • the barbaric experiments carried out by Nazi and Japanese scientists during the second world war
  • the long-running syphilis experiments on black people in Alabama over four decades up to the 1970s.

Clearly these are not 'acceptable'. Thus, our central point in regard to this issue is that the use of cats and dogs who have been bred and caged in laboratory facilities for the purposes of harmful experimentation (never mind the admitted inducement of disease and killing of other animals in experiments) has no acceptable ethical parallel in human studies.

What the ASA have ruled: Firstly, the ASA explicitly disregarded this central point of our complaint. Instead, the ASA state that they considered that readers would understand this claim from IAMS 'to mean that the IAMS research would not deliberately injure or induce disease in animals...', a claim which the ASA appears to believe is true.

Why the ASA are wrong: This is ludicrous. Even if we accept the ASA's and IAMS' perverse interpretation of the policy statement, IAMS themselves contradict this when they admit that they conduct muscle biopsies (and other, unspecified but likely more severe procedures) on cats and dogs, that require analgesia (which may mitigate but unlikely to entirely prevent any pain or discomfort). An invasive, damaging and painful procedure inflicted for research rather than therapeutic purposes is clearly a form of 'deliberate injury'.

Moreover, to return to our central objection to IAMS' statement, the ASA has acknowledged (to us, but fail to mention this important point in their ruling) that IAMS have admitted the caging of cats and dogs in laboratories for several months or years at a time. IAMS themselves admit that this is harmful to animals, and thus this is tantamount to 'deliberate injury'. Most importantly, no acceptable human medical research procedure would knowingly include keeping non-consenting humans for lengthy periods of time in an environment significantly detrimental to their quality of life. Therefore, even before the infliction of procedures, IAMS are conducting research on cats and dogs which would not be ethically acceptable for humans.

Bizarrely, the ASA completely dismissed these issues by stating: 'The question of whether it is appropriate to perform studies of this nature on cats and dogs moves outside the scope of the claims in the ad'. This is total nonsense because IAMS' claims in the ad are all about the appropriateness and acceptability of their experiments on cats and dogs, through their comparison with human studies!


We made some compelling arguments yet, due to either incompetence, conscious or unconscious bias, the ASA has completely dismissed the evidence and arguments we have presented, in favour of a universally indulgent attitude towards IAMS. On every single point, IAMS have been given the benefit of any tiny little bit of doubt. No doubt IAMS have very good lawyers and PR people who probably inhabit the same networks as ASA executives in central London, but if the ASA were fulfilling its role, it should treat each side's assertions with equal scepticism and on the basis of merit, not financial clout.

The adjudication is so one-sided it is hard not to be incredulous and frustrated at the fact that the ASA has essentially given IAMS carte blanche to carry on hoodwinking consumers through half-truths and omission, in direct contradiction to the ASA's own code of practice.

It must also be pointed out that the ASA appears to systematically operate double-standards in its stance towards animal protection groups compared with animal abusers. While the ASA has been extremely lenient towards IAMS, they consistently adopt a much stricter attitude to the requirements for substantiation of claims when animal protection groups are the subject of a complaint.


Uncaged Campaigns 19.04.06


Uncaged 1993-2012: This is the archived website of Uncaged. All information correct at the time of archiving - November 2012.