Ad description
Claims on www.ecowarmth-sw.com, a website for heating systems, stated "... Independent Tests by a UKAS accredited laboratory, confirm that Ecowarmth Electric Radiators need on average only 14 minutes of electricity per hour to provide a full 60 minutes of required warmth!* Which is amongst the lowest running costs in the UK for radiators of this type. Based on a Standard Tariff (EDF 07.02.12) of 14.05p/KwH (incl. VAT), a typical lounge would cost only 6.60p per hour to run. *When measured over a 24 hour period - see downloads for summary of report ...". This text linked to a page with the heading "Electric Radiator information downloads". One of the downloads was headed "2. Comparison of running costs". Text in the download stated "Ecowarmth Heating System. Kw required 2.0 Kw. Tariff: Southern Electric Standard, Band B = 13.26p per kWh (incl. VAT). Calculation 2.0Kw x 24 hrs x £0.1326/kwh x 23.7%* = £1.51 per day". Text underneath the calculation stated "* equates to 14.02 minutes of electricity usage for each hour of heat required".
On a page headed "How it works" text stated "... In "top-up mode", the radiator will use on average only 14 minutes per hour of electricity to provide a full 60 minutes of warmth* ...". Text underneath stated "*Figures based on independent tests carried out by Advantica a UKAS accredited company. Download the Test Report Summary below for more details ...". The website contained a downloadable copy of the Test Report Summary.
On a page headed "German Electric Radiators", text stated "Independently tested in an actual house in the UK by a UKAS accredited laboratory. The tests confirmed that the Ecowarmth range of electric radiators only require on average 14 minutes of electricity per hour to provide a full hour of heat (when measured over a 24 hour period) ...".
Issue
Cornwall Heating Ltd challenged whether the various claims that the product used on average 14 minutes of electricity to provide an hour of heating were misleading and could be substantiated.
Response
Ecowarmth (SW) Ltd provided a copy of a report from an independent testing company, which they believed substantiated the claim.
Assessment
Not upheld
The ASA considered the test report provided. We understood that testing had been carried out by an independent third party on a test house which was considered as having average levels of insulation and was specifically built to represent an average dwelling for test purposes. The report set out a plan of the house and included room dimensions and u-values for the external walls, windows, front doors, patio doors, ground floor and roof. We understood that the room dimensions and u-values were within the average range. The testing was carried out over a three-day period in November and outside temperatures were measured continuously throughout the period and ranged from between 3.5 and 13.5 degrees Celsius. We understood that Ecowarmth electric radiators ranging from 0.5 kW to 1.2 kW were installed throughout the house. The radiators had internal thermostats and were set to between 16 and 21.5 degrees Celsius depending on the size of the room being heated and how the room would be used in a normal domestic setting. For example, the landing radiator was set to 16 degrees, whereas the living room was set to 21 degrees.
We understood that Ecowarmth had tried to simulate typical domestic conditions. For example, the oven and TV were switched on for certain periods of the day to simulate a normal household. The window in one of the bedrooms was deliberately left open during the test as a significant heat loss factor since in a normal household heat would be lost with people entering and leaving the property. We also understood that Ecowarmth considered their figures conservative since in most households the heating would be turned down overnight whereas during the test the thermostats were not altered during the night time. They also noted that the front porch, which faced North, was an area of significant heat loss.
We understood that the radiators were storage heaters and would switch on when the temperature in the room dropped below the level set by the internal thermostat. The heat generated was then stored in the radiator and slowly released into the room. We understood that kWh readings were recorded for the duration of the test period, which represented how much electricity the radiators used. The readings were averaged out over a 24-hour period. The electricity used figure was compared with the total electricity the radiators would have used if they had been ‘on’ the entire time. We understood the radiators used 23.3% of the total electricity they would have used had they been ‘on’ continuously for 24 hours. On a per hour basis, 23.3% of 60 minutes represented 14 minutes of electricity. We considered that because the claims made clear that the 14 minutes of electricity per hour figure was an average measured over a 24-hour period and were based on an independent test, and because the test methodology used was sufficiently robust and mimicked normal domestic use, the claims had been substantiated and were not misleading.
We investigated the claims under CAP Code (Edition 12) rules 3.1 3.1 Marketing communications must not materially mislead or be likely to do so. (Misleading advertising), 3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation. (Substantiation) and 3.11 3.11 Marketing communications must not mislead consumers by exaggerating the capability or performance of a product. (Exaggeration) but did not find them in breach.
Action
No further action necessary.
