With more consumers looking to cut their energy bills and reduce their carbon footprint, solar panels, heat pumps and battery storage are attracting a lot of attention — and a lot of advertising that aim to highlight meaningful benefits. If you’re promoting greener homes products, it’s worth taking a moment to make sure your pricing and savings claims are as clear and accurate as they need to be.
Here we’ll run through some general principles and recent rulings that have touched on these points, all of which also refer to the Competition and Markets Authority (CMA) guidance ‘Marketing green heating and insulation products: Consumer law compliance advice for businesses’.
Pricing
Price is often the first thing consumers look for, so it’s essential that the figure you present is realistic. If a price only applies in limited circumstances, or if additional charges are always required, this needs to be made clear at the point the price is presented (a bit more on qualification later). Consumers shouldn’t have to follow a series of complicated steps to understand what they’ll actually pay.
While it might be possible to show that solar panel packages were sold ‘at’ or ‘below’ a pricing claim, you’ll still need to make clear when that price might be affected by a consumer’s individual circumstances, or if a government grant has already been applied to it.
In addition, any pricing claims should align with the product that’s shown in the ad, so including an image of an 8-panel system when a solar panel savings claim has been based on a 10-panel one, is likely to be a problem.
Savings, savings, savings
Savings claims are designed to be eye-catching, but it’s important to ensure that those savings are achievable and caveated to account for any restrictions or scenarios that it might apply to.
Traditionally when using “up to” or “from” claims, advertisers need to hold evidence that a significant proportion of customers can actually achieve the maximum saving. What amounts to a significant proportion will need to be considered on a case-by-case basis, but in a greener homes context a lot will depend on the specific claim being made and how it’s likely to be interpreted. That will then inform the type of evidence that’s likely to be needed to back it up.
For example, substantiation for very general, unqualified claims like “save up to £546”, “Shrink your electricity bills by up to 94%” or “save up to £1,341 in bills”, will likely need to take the form of a much broader and higher level evidence base, on the basis that it suggests a much broader application of the saving, to a wider range of customers. Where claims are based on a narrow set of circumstances and associated data, that needs to be clear.
Language is also important here. How are consumers likely to interpret terms like “Drastically” in the context of reducing bills? Is that likely to be open to too much interpretation and over-stretch the amount of savings you’re offering? Consumer knowledge of claims like “low-carbon homes” might need to be taken into account when describing bill savings, and how that claim might be presented in an ad.
An important takeaway here is that substantiation was held in all of these cases, and that substantiation would’ve reasonably supported a claim, just not necessarily the specific claim that was made. Which is why there’s…
…the need to qualify
Price statements shouldn’t mislead by omission, and the basis of any price comparisons should be made clear. If you’re comparing your prices or savings to a competitor, a previous price, or an alternative energy source, you’ll need to make sure consumers can easily understand what’s being compared and why.
The savings claims in each of the above cases were based on specific sets of data, some of which were modelled, which would be considered material information that needs to be made clear in the ad. This helps provide more context to the claim, narrowing it’s focus and allows consumers to make an informed decision.
What can be useful when thinking about how to present these types of claims is taking a step back from the creative process at the initial stages and approaching it from a different angle. What evidence do you currently hold and does that help support the claim you want to make? Should the basis of the claim be made clear? What evidence would you need to help substantiate a different claim and is that achievable?
In short
Greener‑homes products can offer real benefits, but the advertising that promotes them needs to give consumers the full picture. That means being realistic about savings, transparent about pricing and clear about comparisons.
If you need any additional support on any non-broadcast ads, contact CAP’s Copy Advice team.
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