Ad description

A magazine ad for Bremont Chronometers, seen on 5 November 2017, promoted the Supermarine Type 301 watch. The ad stated in text that ran down the page "The new Supermarine Type 301 has been hand-built and tested on British shores, at our headquarters in Henley-on-Thames". The ad featured a Union Jack flag at the bottom of the ad, alongside text which stated “British Engineering. Tested Beyond Endurance”.

Issue

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

1. that the Supermarine Type 301 was hand-built; and

2. that the Supermarine Type 301 was built in Britain.

Response

1. Bremont Watch Company Ltd t/a Bremont Chronometers said they manufactured (which included case manufacture, polish and finishing) and assembled more than 10,000 watches. They provided videos that showed the parts of the Supermarine Type 301 being made, finished, assembled and tested at their factory. They also provided photographs of the Supermarine Type 301 cases being manufactured out of a steel bar, their 11-axis CNC mill-turning machine and digital lathe manufacturing equipment.

2. Bremont Chronometers said at least 60–70% of their materials and labour for the Supermarine Type 301 was British sourced. They said the movement in the watch was sourced from Switzerland, although some of the movement parts were finished and decorated in the UK. They added that the movement was only one part of the watch's make up. They said the watch was designed and assembled in the UK, the movement parts inside of the case were finished in the UK, and the whole case (apart from the ceramic bezel and crown) and the movement mount and internal workings of the case were also made in the UK.

Bremont Chronometers also said the Supermarine Type 301's leather packaging and its outer packaging were made in Manchester. They added that all their watches were marked with the word "London" on the dial and that they were not permitted to mark their watches "Swiss made".

Assessment

1. Not upheld

We considered that consumers were likely to interpret the claim "hand-built" to mean that the watch was manufactured and constructed by hand, but that mechanical tools and machinery would also be used, given that the product was mostly comprised of metal and electronics. We considered that consumers would expect a significant proportion of the production process would have relied on the manual skills and control of the engineers and staff.

We assessed the evidence provided by Bremont Chronometers, which showed a number of stages during the manufacturing process. We noted the photographs and video showed the watch cases being manufactured out of a steel bar, the use of digital lathe manufacturing equipment and computerised machinery. We also viewed the watch undergoing individual assembly between a team of engineers.

Although we noted that the production of the watches included machinery such as digital lathe manufacturing equipment, we considered the photographs demonstrated that such equipment was used by engineers as tools and that the manner in which the main components were constructed relied primarily on the manual control and skills of the engineers and did not involve large scale automated machinery.

On that basis, we concluded the claim "hand-built" had been substantiated and was not misleading.

On that point, we investigated the ad under CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  and  3.3 3.3 Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that the consumer needs to make informed decisions in relation to a product. Whether the omission or presentation of material information is likely to mislead the consumer depends on the context, theĀ  medium and, if the medium of the marketing communication is constrained by time or space, the measures that the marketer takes to make that information available to the consumer by other means.
 (Misleading Advertising) and  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), but did not find it in breach.

2. Not upheld

The ASA considered that consumers would interpret the claim "hand built and tested on British shores" to mean that the majority of the main components of the watch, although not necessarily all of the individual components, were constructed and assembled in Britain.

We noted from the evidence provided by Bremont Chronometers that the watch was assembled and tested entirely in Britain, and considered that the assembly process was a significant part of the production process. We further understood that the majority of the main components (apart from the Swiss movement, the case's ceramic bezel and crown) were sourced from Britain.

Because consumers were likely to understand the claim to mean that at least the majority of the main components were built and tested in Britain, when the evidence showed that both the majority of components were sourced from around Britain and that the watch was assembled, tested and finished at Bremont's headquarters in Britain, we concluded the ad was unlikely to mislead.

On that point, we investigated the ad under CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  and  3.3 3.3 Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that the consumer needs to make informed decisions in relation to a product. Whether the omission or presentation of material information is likely to mislead the consumer depends on the context, theĀ  medium and, if the medium of the marketing communication is constrained by time or space, the measures that the marketer takes to make that information available to the consumer by other means.
 (Misleading Advertising) and  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), but did not find it in breach.

Action

No further action necessary.

CAP Code (Edition 12)

3.1     3.3     3.7    


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