Background

Misleading Advertising: Travel Affairs Ltd breaks the UK ad rules for not making clear on the ehic-e111-card.org website (namely https://ehic-e111-card.org:9449/NewApplication_Form.aspx?nhs=REN) that it is not the official government channel for applications for the European Health Insurance Card (EHIC).

The CAP Compliance team has been taking market-wide action about the advertising of official services or documents on websites that are not the official government channel, including websites for EHICs. The EHIC is available free of charge via www.gov.uk or the NHS Choices website: http://www.nhs.uk/NHSEngland/Healthcareabroad/EHIC/Pages/about-the-ehic.aspx/.

ASA research and subsequent ASA rulings have found that consumers were likely to infer that a website providing application services for, or a platform to obtain, government-issued documents or services was official, unless it made clear that this was not the case.

Amongst other requirements, websites should make clear their unofficial status by including a prominent disclaimer alongside calls to action, which should allow consumers to understand the non-official nature of the service and the additional cost of using that service compared to using the official service directly. Disclaimers should be prominent and separate from other information, and appear alongside calls to action and the most prominent price statements on each page.

There is no prominent disclaimer on the https://ehic-e111-card.org:9449/NewApplication_Form.aspx?nhs=REN page to make clear the website is not affiliated to the NHS or the UK government. Furthermore, there is no clarification that the cost of using Travel Affairs Ltd’s service (£24.99) is more expensive than using the free official service directly.

The CAP Compliance team has been in contact with Travel Affairs Ltd but they have not responded by the requested time, and the ehic-e111-card.org website continues to breach the Code. Because of this continued non-compliance, we took the decision to place their details on this section of the ASA website on 6 February 2018. These details shall remain in place until ehic-e111-card.org has been appropriately amended to ensure compliance with the CAP Code.


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