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ASA Adjudication on GDC Group Ltd

GDC Group Ltd t/a Dimplex

Millbrook house
Grange Drive
Hedge End
Southampton
Hampshire
SO30 2DF

Date:

30 January 2013

Media:

Brochure, Internet (on own site)

Sector:

Household

Number of complaints:

1

Complaint Ref:

A12-204744

Background

Summary of Council decision:

Four issues were investigated, all of which were Not upheld.

Ad

A leaflet, downloadable from the website www.dimplex.co.uk, promoted storage heaters. The first page was entitled "How much do you know about Dimplex electric storage heating?" and contained a list of "Electric Storage Heating Facts", which included: "5. The performance of a Dimplex storage heater will not deteriorate over time", "9. Running on off-peak electricity Dimplex storage heaters will always be cheaper over a 16 hour day than direct acting heaters on the day-rate", "11. Dimplex storage heaters, like other electric space heaters are 100% efficient - unbeatable by traditional heating methods" and "13. Static Dimplex storage heaters have no moving parts and are maintenance-free for life".

Issue

The complainant challenged whether the following claims were misleading and could be substantiated:

1. "The performance of a Dimplex storage heater will not deteriorate over time";

2. " Running on off-peak electricity Dimplex storage heaters will always be cheaper over a 16 hour day than direct acting heaters on the day-rate";

3. "Dimplex storage heaters, like other electric space heaters are 100% efficient - unbeatable by traditional heating methods"; and

4. "Static Dimplex storage heaters have no moving parts and are maintenance-free for life".

CAP Code (Edition 12)

Response

1. GDC Group Ltd, trading as Dimplex (Dimplex) responded that storage heaters were designed to take in electrical energy and convert it into thermal energy (heat) by heating a "core" to a high temperature, which was typically around 600–700 degrees C. They explained that the core was sufficiently insulated to allow the heat to be released slowly into the surroundings over a 24-hour period. As such, the primary components of storage heaters were essentially passive and would retain their integrity through many years of service. They said the average age of Dimplex storage heaters in service was in excess of 25 years.

Dimplex outlined the primary components of their storage heaters. They stated that the heating elements were resistive wire cores insulated with magnesium oxide, and that, because the physics of resistive heating dictated that the heating effect was always directly proportional to the electrical resistance, there would be no deterioration in the effect produced by the heating elements over time. They said the core of their storage heaters consisted of a number of storage bricks manufactured with specific ingredients engineered to ensure they retained their integrity over many years without degradation.

A further component was the heaters' thermal insulation, which Dimplex said consisted of a high-performance material suitable for temperatures of up to 1000 degrees C. They provided a copy of a sales brochure from the manufacturer of the insulation which stated that it would not deteriorate with age. With regards to the electromechanical controls, which formed the final primary component of the heaters, Dimplex explained that all of these devices had been designed in accordance with European standards. These stipulated that their operating characteristics did not change with time or service and had been approved for over 10,000 cycles of use. They said the outer casing of the storage heater unit was protected with a powder-coated paint finish designed to resist corrosion in any normal domestic environment over many years.

In relation to the performance of their storage heaters, Dimplex stated that because storage heaters worked on the principles of electrical resistance, which was a physical constant, they would always convert the energy input into heat at 100% efficiency. They explained that the Government's Standard Assessment Procedure (SAP), which was a method of assessing the energy rating of dwellings published by the Buildings Research Establishment (BRE) on behalf of the Department of Energy and Climate Change (DECC), listed storage heaters as being 100% efficient and did not impose a time limit on that statement.

2. Dimplex stated that the claim "Running on off-peak electricity Dimplex storage heaters will always be cheaper over a 16 hour day than direct acting heaters on the day-rate" was intended to communicate that consumers who had any form of off-peak (time-of-use) electricity tariff in place would achieve the lowest possible running costs of electric heating over a 16-hour period by using storage heaters in preference to direct acting heaters exclusively. They explained that time-of-use tariffs aimed to make electricity more affordable by providing it during off-peak periods with correspondingly cheaper rates, and that of the time-of-use tariffs currently available in the UK the most popular was the Economy 7. Dimplex provided data extracts from a publication which they said was intended to compare different domestic fuels and the costs of using those, and which had a reputation as an independent and impartial source of fuel and heating cost data. The extracts gave a fuel purchasing cost per useful kWh for various types of fuel, separated by region. The costs per unit for purchasing electricity on an off-peak time-of-use tariff were lower than those for both the on-peak and unrestricted (non-time-of-use) tariffs. Dimplex stated that to provide 16 hours' worth of heat at an average of one kW, a storage heater would need to be charged for seven hours overnight, whereas a direct-acting heater would need to be turned on for 16 hours. Therefore, it was accurate to claim that storage heaters running on off-peak electricity would always be cheaper over a 16-hour day than direct acting heaters on the day-rate.

Although Dimplex acknowledged that the data provided average costs only, and for specific regions of the country, they pointed out that the function of time-of-use tariffs was to provide cheaper electricity during off-peak hours, and that therefore it was clear that a storage heater able to take all of its charge during the off-peak period would always cost less to run than a direct acting heater needing to use electricity at peak times on an unrestricted or day rate.

3. Dimplex provided an extract from the SAP for the energy rating of dwellings, which they stated listed electric storage heaters as being 100% efficient. They said traditional heating methods, by which they meant fossil-fuelled appliances, did not achieve the same efficiency ratings.

4. Dimplex stated that in making the claim "Static Dimplex storage heaters have no moving parts and are maintenance-free for life", they had intended to communicate that in normal operation of the product there was no element which continuously had to move in order to enable the provision of heat or which was prone to wear out within the lifetime of the appliance and therefore require servicing or routine maintenance.

They acknowledged that the heaters did contain a small number of electrical components which would move on occasion; these included safety cut-out and temperature control mechanisms, although they pointed out that the recommended usage of a storage heater was to "set and forget" the temperature and therefore they did not anticipate that that mechanism would be frequently adjusted. They stated that occasionally some components might fail prematurely before the end of the economic life of the appliance, and that spare parts were therefore available, but said no routine servicing or maintenance was recommended during the lifetime of the product either by the user or a professional.

Assessment

1. Not upheld

The ASA considered that the claim "The performance of a Dimplex storage heater will not deteriorate over time" was likely to be interpreted by consumers as meaning that there would be no noticeable difference in the heat output of that product during its life cycle. We understood that the main components of storage heaters were passive and designed to last for many years without degradation. We acknowledged Dimplex's statement that energy input would always be converted to heat at 100% efficiency because storage heaters worked on the principle of electrical resistance, which was a physical constant. We contacted the DECC for their views on this claim. They responded in conjunction with the BRE; both parties said it was accurate to describe electric storage heaters as being 100% efficient in converting electricity to heat, and that that conversion rate would remain constant over time. Because we understood that the heater would always function at an efficiency rate of 100% from electricity to heat, and because we also understood that the passive components had been designed to function at the same level for the life cycle of the product, we concluded that the claim "The performance of a Dimplex storage heater will not deteriorate over time" was not misleading.

On that point, we investigated the ad under CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising) and 3.7 (Substantiation) but did not find it in breach.

2. Not upheld

We understood that a Dimplex storage heater would have to be charged for seven hours in order to produce 1 kW of heat for 16 hours, whereas a direct-acting heater, because it did not have the capacity to store heat, would need to be turned on for the entirety of that period. We noted the data provided by Dimplex, which showed the comparative prices of electricity on on-peak, off-peak and unrestricted rates and, although we acknowledged that those showed region- and supplier-specific instances only, we considered it was nevertheless reasonable to state that, for any given time-of-use tariff, the off-peak rate would always be cheaper than the peak rate.

We considered that the claim "Running on off-peak electricity Dimplex storage heaters will always be cheaper over a 16 hour day than direct acting heaters on the day-rate" made clear to consumers that the comparison was based upon some form of time-of-use tariff, whereby storage heating, charging in an off-peak period, was compared to direct-acting heaters used during the day on a day-rate. Because we understood that storage heaters were able to make use of off-peak electricity tariffs to deliver heat during the day where direct acting heaters were not, and because off-peak time-of-use tariffs were by their nature cheaper than the on-peak day rates, we concluded that the claim was not misleading.

On that point, we investigated the ad under CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising) and 3.7 (Substantiation) but did not find it in breach.

3. Not upheld

We considered that the claim "Dimplex storage heaters, like other electric space heaters are 100% efficient - unbeatable by traditional heating methods" implied that all of the energy input to the appliance would be converted into heat, and that traditional heating methods would not be able to achieve a more efficient conversion rating than that. We understood that GDC had intended the comparison to refer to fossil-fuelled appliances, and considered that was consistent with the average consumer's likely interpretation of the phrase "traditional heating methods".

We noted that the extract of the SAP documentation provided listed electric storage heaters as being 100% efficient. We asked the DECC and BRE for their views on the claim. Both parties stated, as noted in point 1 above, that electric storage heaters converted electricity to heat at 100% efficiency. However, they also pointed out that the generation of grid electricity relied in most cases upon the burning of fossil fuels. They therefore said the conversion losses to which traditional, fossil-fuelled heating appliances were subject would still occur when electric storage heaters were used, but at the power station rather than in the home.

We noted that it was accurate to describe electric space heaters as being 100% efficient in the conversion of electricity to heat. Although we acknowledged that the conversion losses experienced by fossil-fuelled appliances would nevertheless still occur when electric storage heaters were used, we considered that the claim related to the individual user's experience of the heaters and did not go so far as to imply that the generation of the electricity itself was 100% efficient. We understood that, with the exception of heat pumps, fossil-fuelled heating appliances did not convert the energy input to heat at a rate greater than 100%, and we considered that heat pumps were unlikely to fall within the average consumer's understanding of the term "traditional heating methods". For those reasons, we concluded that the claim "Dimplex storage heaters, like other electric space heaters are 100% efficient - unbeatable by traditional heating methods" was not misleading.

On that point, we investigated the ad under CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising) and 3.7 (Substantiation) but did not find it in breach.

4. Not upheld

We considered that the claim that static Dimplex storage heaters had no moving parts, in the context of a sentence referring to their being maintenance-free for life, was likely to be understood by consumers as meaning that the appliances did not rely on any moving parts in order to store and dispense heat. We noted that that was the case, and although we acknowledged that they did nevertheless contain some moving parts, we understood that those would not routinely move during the operation of the appliance and therefore did not consider that their existence would materially affect the average consumer's understanding of the claim.

We noted Dimplex's statement that no routine maintenance or servicing was recommended during the lifetime of the heaters, but that spare parts were nevertheless available in view of the fact that some components might fail prematurely. We considered that, as with other electrical appliances, the average consumer was likely to be aware of that possibility and would interpret the claim "maintenance-free for life" as referring to regular or scheduled servicing and maintenance required to keep the appliance working effectively.

Because we were satisfied that the average consumer would understand the claim to mean that no parts in the heaters moved in order to store and release heat and that no routine maintenance was required, and because we understood that that was the case, we concluded that the claim "Static Dimplex storage heaters have no moving parts and are maintenance-free for life" was not misleading.

On that point, we investigated the ad under CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising) and 3.7 (Substantiation) but did not find it in breach.

Action

No further action necessary.

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