Decision of The Advertising Standards Authority of Ireland to require Unilever to pull its Flora advertorial in The Irish Daily Mail is regrettable

Letter from to Advertising Standards Authority for Ireland re: ASAI finding ref no. 19340 for unknown complainant regarding ‘Unilever’ presses advertorial for ‘Flora’ spread and active lifestyle’ is the umbrella body for the various cycling advocacy groups throughout Ireland. We are the member for Ireland of the European Cyclists’ Federation. Our goal is to see a vast increase in the numbers of Irish people using their bike for work, shopping or socialising. The benefits of increased cycling are many: population health; personal and public cost savings; better traffic flow; environmental improvement, and better ‘liveability’ of our towns and cities. Our mission is to inform the Irish public and officialdom of these benefits, and the simple changes – engineering, education enforcement and others, required to reap them.

We write to object strongly to the recent finding of the Authority, Ref No. 19340 on the ASAI website, that an advertising feature (Unilever ‘Flora’ spread) in The Irish Daily Mail showing a family cycling in a park-like setting (not on a road) was in contravention of the Authority’s Code section 2.29. The complaint was that the group were not shown wearing helmets. The behaviour illustrated is in fact much healthier than the average Irish lifestyle, and is to be encouraged. Letter from to Advertising Standards Authority for Ireland re: ASAI finding ref no. 19340 for unknown complainant regarding ‘Unilever’ presses advertorial for ‘Flora’ spread and active lifestyle It does NOT constitute dangerous behaviour or unsafe practice, in our view. We note that motor vehicles being driven at speed are a constant inescapable feature of advertising and would challenge the Authority to show that all complaints to it regarding all examples of unsafe motoring have been justly upheld.

The encouragement of widespread cycling is not just our policy, but Government policy too, as set out in the National Cycle Policy Framework of 2009. The government has set a target of 10% of commuting trips to be made by bike by 2020. []

Other statutory and advisory documents such as the Institute of Public Health’s ‘Building Young Hearts’ make it very clear that all measures to promote active transport are, particularly for children, very valuable to Irish society at large. The subject image in the Flora advert is actually a great illustration of the enjoyment, sociability and health benefits of cycling and deserves to be promoted, not suppressed. This country has a morbidity time-bomb lurking within it due to the high incidence of overweight and obesity in the population due to far too sedentary life-styles. A recent study has found that 26% of Irish 9-year olds are overweight/obese. [ESRI, 2011. ‘Growing Up in Ireland’] Unilever was trying to promote an active lifestyle with this advertorial and should not be punished for its efforts. We have received a copy of the advert from Unilever UK management so we know what was depicted.

To realise this value, cycling must become a normal part of more Irish peoples’ everyday life. Normal, transportation cycling does not require particular safety equipment or outfits. We recognise that helmets can offer some protection in certain kinds of road accident, but hold it as obvious that what’s really needed to improve road safety is safer use of motor vehicles, lower speed limits and better-trained drivers. Over-emphasis on lesser issues such as personal protective equipment of dubious value distracts vital attention from this main focus. is in no way opposed to personal choice to use a helmet. We note, though, that there is substantial international controversy among researchers and policymakers over the efficacy of helmets as a safety measure for cyclists, while in contrast there’s no doubt that laws requiring them have the effect of reducing cycling numbers. Any such reduction in cycling activity due to mis-promotion of helmet use, by compulsion, increases public health problems such as overweight, heart disease, etc. A recent study showed that the 1994 helmet law in New Zealand, for example, is responsible for 53 additional premature deaths there annually, due to its suppressing effect on active travel and physical exercise. There is little likelihood of such a regulation being introduced in Ireland, but public decisions – like your decision in this case – reinforce the ‘dangerisation’ of cycling and delay progress towards a healthier, cleaner and more economically efficient Ireland.

We would further point out that recent significant increases in cycling in central Dublin are widely acknowledged – notably by Road Safety Authority chief executive Noel Brett and senior Gardaí – to have resulted in safer streets for ALL road users. The Dublin Bike scheme does not require helmet-use. It follows that lowering of cycling numbers will increase the risk for any remaining cyclists. While we applaud the RSA’s record at reducing road fatalities in recent years, there are concerns that an excessive emphasis on helmet use, which deters people from cycling by exaggerating the risks, ultimately reduces population health, and may delay the spread of those improvements in road safety that need to be directed at drivers.

We also wonder whether the Authority has distinguished between the RSA’s promotion of helmets for road use and cycling off-road at slower speeds. Were the RSA consulted specifically about the image in question? The fact that the image under complaint did not in fact feature road use raises questions about taking RSA’s viewpoint into account in your deliberations. The RSA’s jurisdiction is for road safety and not off-road activity. We are engaging separately with the RSA, to seek to moderate their emphasis in road-safety publicity, to limit ‘dangerisation’ of cycling, and are copying Mr. Brett, the CEO of the RSA, herewith.

We call on the ASAI to educate its Board, Secretariat, and Complaints Committee members about the benefits of cycling and the down-side of showing cycling as an abnormal, hazardous activity requiring disproportionate levels of personal protective equipment. We seek your confirmation that in future such complaints will be rebuffed. We would be glad to provide materials and information for such education.

We would refer you to a recent advertisement on RTE 1 TV for KBC Bank that depicts a car pulling into a road-side cycle track delineated by a continuous white line. No vehicle is permitted to come into such a cycle track. It is a penalty-point offense. You can see it here:

In our view this advert should be ‘pulled’ because it depicts an illegal act under road traffic law. The point will not be lost on the ASAI that there is no law requiring cyclists to wear a helmet whereas there is a law against vehicles crossing into cycling facilities. In making this decision the ASAI was giving far too much credence to the views of the RSA. We would ask the ASAI to learn from this regrettable decision.

6 thoughts on “Decision of The Advertising Standards Authority of Ireland to require Unilever to pull its Flora advertorial in The Irish Daily Mail is regrettable”

  1. It is hard to believe a complaint is upheld against this image. It sets a interesting standard as I sure all car adverts could therefore be banned because motorists are not wearing helmets and have no hi viz stripes on the cars. Maybe it’s time to start the court case for speed limiters on any car capable of exceeding the speed limit because the design of that car is dangerous because the RSA speed limit should not be broken

  2. The decision shows how badly informed organizations like this are. How even a afternoon spent researching a subject can get such a poor decision. Government are so terrified to change any decision

  3. I wonder if the ASAI would also have addressed questions about the safety of jogging in parks without heart rate monitors to the RSA?

    Hopefully the out-of-focus image in the KBC spot of a cyclist making rather more headway than the aspiring taxi user (21 seconds in) will register with viewers. Until such time as we get better cycling promotion, we will have to be grateful for even these little subliminal messages.

  4. I, personally, always advocate the use of a helmet while cycling. In my opinion its good practice. Having said that, I think this decision is ridiculous.
    As was stated, it is not illegal and they are obviously not on a public roadway. If every individuals perception of a dangerous activity in everyday life were treated the same way things would get out of control.

    It’s not illegal to eat fast food yet we are bombarded by such practices regularly on adverts- even though obesity has a higher fatality in Ireland than traffic accidents! TV programs constantly portray people enjoying alcohol – Woolpack, Rovers Return,Queen Vic,Molloys – does this mean we are at risk from alcoholism as a result?

    A balanced view is required with a dose of common sense. One swallow doesn’t make a summer.

  5. While I agree with most of the points made in the letter and indeed the broad thrust I have to say that I am disappointed that the old argument that excessive emphasis on helmet use may delay the spread of those improvements in road safety that need to be directed at drivers has surfaced again.

    I have argued elsewhere that this particular argument is disingenuous in that it attempts to use a negative to prove a positive. If there is controversy in relation to the efficacy of helmet use in the first instance then there are clearly two sides to the argument. That being the case I cannot see how this particular argument can be used. The argument clearly implies what side of that particular controversy you come down on.

    The argument surely is that drivers need to be educated full stop! Notwithstanding the claim that you are not opposed to helmet use on a personal basis it seems to me that the emphasis on the negative efficacy of helmets disproves that particular statement.

    Having said all of that this is just a minor gripe with an otherwise excellent letter.

  6. Excellent Letter and points well made. If I could add maybe you should have asked for CEO of RSA to tender his resignation. In this instance they were pursuing a point that is not government policy, indeed as stated in your letter it was opposed to government policy and waste of time and the public purse. In these times public servants need to do a good job for all road users and not fixate on personal “helmet fetishes”. I am going to send a quick note to Flora PR department to thank and congratulate them on promoting healthy cycling and to ask them not to cave in to officious bulling so easily in the future. I would suggest others might do the same. Keep up the good work

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