ASA Adjudication on Solar Twin Ltd

Solar Twin Ltd

50 Watergate Street
Chester
Cheshire
CH1 2LA

Date:

14 December 2011

Media:

Internet (on own site)

Sector:

Household

Number of complaints:

Complaint Ref:

A11-169818

Claims on the Solar Twin website, for a solar panel retailer, viewed on 25 August 2011, featured text that stated "Solartwin.com zero carbon solar power & water heating ... ".

Issue

The complainant challenged whether the claim "Solartwin.com zero carbon solar power & water heating" was misleading and could be substantiated.

CAP Code (Edition 12)

11.43.13.7

Response

Solar Twin believed the ad did not state or imply that the manufacturing process produced zero carbon and further stated that all manufactured products would produce carbon at the manufacturing stage. They referred the ASA to a publication entitled "Photovoltaics in the UK: An introductory guide for new consumers" and said the report made clear that photovoltaics produced no carbon dioxide during their operating lifetimes. They also provided the ASA with a report carried out by The Energy Monitoring Company, entitled "Side by side testing of eight solar water heating systems". They said the report showed that their solar hot water system was the only product which used no mains electricity in its operation and was therefore zero carbon during its operation. They said the report also demonstrated that their product reduced carbon emissions over the course of the year. They believed, in the context of the operation of solar thermal, that the zero carbon claim was justified.

Solar Twin sent a report conducted by a third party. They said the report demonstrated the environmental impacts of Solar Hot Water and PV systems at both the production and operation stages. They said the full life cycle impact of the systems was the sum of the environmental impact at production and operation stages. They acknowledged that carbon was emitted in the manufacture of both systems and that the report showed that. However, they said the report showed that the carbon created during manufacture was more than offset during the systems operation. They therefore believed that the zero carbon claim was justified, and even an understatement.

Solar Twin sent a statement provided by a third party. They said the statement made clear that energy use in the context of power and heating technologies used in homes included only operational energy use and did not include embodied energy. They therefore believed that in the context of Building Regulations "zero carbon technology" was defined as a product that emitted zero carbon during its operation and said their products exceeded that definition.

Solar Twin said the term zero carbon was used outside the UK and provided the ASA with several documents that included the term.

Assessment

Upheld

The ASA noted Solar Twin's comments that carbon was produced in the manufacture of their products and that that was offset during their operation. We also noted their comments that in the context of building regulations, zero carbon technology was restricted to operational energy use. However, we noted that within the Defra research paper, dated February 2011 and entitled "Consumer understanding of green terms", only 46% of respondents stated they were very familiar or familiar with the term zero carbon. We noted that the report commented that "If unsure, participants often interpreted terms in their most literal sense (e.g. 'zero carbon' was often translated in the group discussions as 'emits no carbon')." We also noted the ad was for a solar panel supplier and considered that the availability of a product which produced zero carbon during its full life cycle was likely to be a factor that would effect a consumer's transactional decision. Therefore in the context of the ad, we considered that consumers were likely to interpret the zero carbon claim to mean that no carbon was produced in the full life cycle of the advertised products.

Since we understood that carbon was produced in the manufacturing process, we concluded that the zero carbon claim had not been substantiated and that the ad was likely to mislead consumers to their detriment.

The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 11.4 (Environmental claims).

Action

The ad must not appear again in its current form. We told Solar Twin to ensure that all zero carbon claims were capable of robust substantiation in future.

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