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ASA Ruling on SKS Consultancy (Manchester) Ltd

SKS Consultancy (Manchester) Ltd t/a

St Baldreds House
239 Ashley Road
WA15 9NE


30 January 2013


Internet (on own site)



Number of complaints:


Complaint Ref:



Summary of Council decision:

Three issues were investigated, all of which were Upheld.


A website,, for a company which installed thermodynamic heating devices, stated "Confirmed our industry experts: 'Don't Buy Solar Thermal' Why? Solar thermal systems are now yesterday's technology. It's a fact! Instead, generate your own 100% FREE Hot Water that's 'ZERO' water heating bills for 25 years for your home and family".

An animated video embedded on a further web page gave information about the system, and included the claim "Has a COP of up to 1-7". A comparison table beneath the video, headed "Comparison Table: Renewable Source SKS Thermo Vs Air Source Vs Solar Thermal", showed SKS Thermo outperforming Air Source and Solar Thermal in all areas, including "Provide 100% of FREE Hot Water Needs". Text stated "BEST DEAL" and "Rank #1" for SKS Thermo.


The complainant, who worked in the renewable energy industry, challenged whether the claims:

1. "100% FREE Hot Water" and "Provide[s] 100% of FREE Hot Water Needs" and

2. "Has a COP of up to 1-7"

were misleading and could be substantiated.

3. The complainant also challenged whether the comparison with air source and solar thermal systems was fair, because it implied that SKS Thermo was superior to those forms of heating but did not include criteria such as energy performance.

CAP Code (Edition 12)


1. SKS Consultancy (Manchester) Ltd (SKS) said they accepted that there was a cost to running the system and they would remove the claim.

2. SKS provided a document which listed the technical specifications of SKS Thermo systems for central heating or swimming pool heating; the document was a page from the manufacturers' installation manual. The document stated the "Absorbed power" and "Supplied Power" for systems with varying numbers of panels installed. From that information, SKS calculated that a central heating system using four panels had a COP (coefficient of performance) of 7.59.

3. SKS provided two documents in relation to the COP ratings of solar thermal and air source heat pumps. One, a screenshot of the website of an air-to-water heat pump manufacturer, stated that every 1 kW of electricity used to operate their pump could provide up to 4 kW of heat to the property; we understood that equated to a COP of 4. The other document was a page from the brochure of a manufacturer which made a range of renewable heating and hot water products; the page gave the technical specifications for a solar panel for hot water production. SKS said it showed that the COP for the product was between 2.41 and 3.32.


1. Upheld

The ASA understood that the SKS system used electricity and therefore there were costs to running the system. We concluded it was misleading to state or imply that the systems provided "free" hot water. We welcomed SKS' willingness to remove the claims.

On this point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 3.11 (Exaggeration).

2. Upheld

We understood that a COP rating indicated energy efficiency and was calculated by dividing the heat output of the system by the amount of energy required to power the system; the higher the COP, the more efficient the system. We understood that the COP of a system could vary depending on the particular conditions of each specific installation and it might therefore be reasonable to quote a COP range for a system rather than stating a specific figure. However, we considered that advertisers who stated COP figures must be able to substantiate, with robust evidence, that the quoted COP figure/range could be achieved by consumers.

We reviewed the data from the manufacturers' technical specifications document, on which SKS had based their COP calculation. We were concerned that we had not seen any information as to how or where that data had been collected, or under what conditions. We considered the information did not, therefore, constitute robust evidence that the system installed by SKS could achieve a COP of 7.59, as calculated by SKS, or that it could achieve a COP of "up to ... 7" as stated in the ad. We concluded the claim was misleading.

On this point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 3.11 (Exaggeration).

3. Upheld

CAP Code 3.38 required that, when making comparisons with unidentifiable competitors, advertisers must not select elements of a comparison which would give them an unrepresentative advantage. We noted SKS had not provided information with regard to their rationale for selecting the particular elements included in the comparison table, and also had not provided evidence to support the claims included in the table. We noted the information they had provided with regard to the COP figures for one solar thermal and one air source system, but considered that the screenshot (which was taken after SKS' ad was published) and brochure page were not robust evidence on which to base a comparison of COP figures. Furthermore, we noted the table referred to air source and solar thermal systems generally but the information provided by SKS was in relation to one air source and one solar thermal system. We concluded we had not seen evidence to substantiate the claims included in the table, and that we also had not seen evidence to substantiate that SKS had not selected elements of comparison which would give them an unfair advantage; we concluded the ad breached the Code.

On this point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation), 3.11 (Exaggeration) and 3.38 (Other Comparisons).


The ad must not appear again in its current form. We told SKS not to make claims for which they did not hold substantiation. We told them not to make comparative claims where the elements of the comparison were selected to give them an unrepresentative advantage.

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