Ad description
The website of A Love of Humanity, www.aloveofhumanity.co.uk, a human tissue donation service, seen 7 April 2026. On the homepage, text included a “+44” (UK) phone number and a .co.uk email address. Text at the bottom of the webpage included the following address: “St. George’s Works, 51 Colegate, Norwich, NR3 1DD, UK”. Under the subheading, “COST-FREE ALTERNATIVE” text stated, “Body donation offers a cost-free alternative to traditional funeral arrangements. By eliminating the expenses associated with burial or cremation, you can alleviate the financial burden on your family during a challenging time. Additionally, many body donation programs cover the costs associated with the transportation and final disposition of your remains, making the process seamless for your loved ones”.
Further down the webpage, under the subheading “WHAT HAPPENS TO MY BODY AFTER IT IS USED FOR RESEARCH OR EDUCATION?”, text stated, “Once the research or educational purposes are fulfilled, the body will receive respectful and appropriate final disposition. This can include cremation, burial, or permanent collection final disposition depending on the preferences of the donor”.
Issue
The Human Tissue Authority (HTA), who understood the advertiser was based in the Netherlands, challenged whether the ad misleadingly implied that the advertiser was based in the UK.
Response
Fenix Biomed BV t/a A Love of Humanity confirmed that the company was incorporated and registered in the Netherlands, and that A Love of Humanity was a trading name and division of that company. They said they did not have a registered office or incorporated subsidiary in the UK.
They acknowledged that certain elements of the website, including the UK postal address, UK telephone number and .co.uk domain and email address, could give rise to the impression that the business was UK-based. However, they said those details had been used for practical, consumer-focused reasons. They explained that the UK postal address was used as a correspondence address for sending information and consent packs to prospective UK donors, and that the UK telephone number allowed consumers to contact them at local call rates and speak to English-speaking staff. They believed a .co.uk domain and email address to be standard practice for an organisation offering services to UK consumers.
A Love of Humanity acknowledged that the homepage did not state that the company was based in the Netherlands, and that this information appeared only in the downloadable information booklet. They said the booklet was provided to every prospective registrant and that no individual could register without first receiving and reviewing it, because the registration documents were contained within it. They therefore considered that full disclosure was provided at the point of registration. However, they accepted that prospective donors should understand the nature and location of the service before deciding whether to request further information.
They clarified that, once a donor’s body had fulfilled its research or educational purpose, final disposition would be arranged either by them or by the receiving institution, in accordance with Dutch or local regulations. They said remains were not returned to the UK, and that family members were not required or expected to travel to the Netherlands to collect them. They said that, for accepted donors, cremation costs were covered by A Love of Humanity where cremation was the applicable form of final disposition. They confirmed that, where a donation was not accepted, responsibility for burial or cremation would rest with the executors or family members.
A Love of Humanity acknowledged that the website’s current references to a “cost-free alternative” and “respectful and appropriate final disposition” did not explain those arrangements with sufficient clarity, and that prospective donors reading only the homepage could be left with unanswered questions. They said they would amend the website to make clear that A Love of Humanity was a trading name of Fenix Biomed BV, a company based and registered in the Netherlands. They said they would add text which explained the purpose of the UK contact details, clarify the circumstances in which the service was cost-free, and provide clearer information about final disposition and the fact that remains would not be repatriated to the UK.
Assessment
Upheld
The ad, which was the homepage for A Love of Humanity’s body donation service, prominently featured a UK telephone number, email address and physical address. The ASA considered those were strong indicators of a UK-based business, particularly because they appeared on the homepage alongside requests to contact the company. We noted that there was no information on the homepage which stated the company was based in the Netherlands. We therefore considered that consumers were likely to understand from the overall presentation of the ad that the service was based, and operated in, the UK.
However, information elsewhere on the website stated that the advertiser was based in the Netherlands. In particular, the downloadable information booklet stated on page two that A Love of Humanity was “a division of Fenix Biomed BV based in the Netherlands” and that donors would be “transported with care to our facilities in the Netherlands”. That information was not made clear in the ad itself and appeared only in a separate booklet that consumers had to click through to access. We therefore considered the ad implied the company was based in the UK when that was not the case.
We next assessed whether A Love of Humanity’s location was likely to be material to consumers when deciding whether or not to use the service. The ad described body donation as a “cost-free alternative” to traditional funeral arrangements and stated that many body donation programs covered transportation and final disposition costs. It also stated that, once research or educational purposes were fulfilled, the body would receive “respectful and appropriate final disposition”, which could include cremation, burial, or permanent collection depending on the donor’s preferences. However, information in the booklet stated that accepted donors would be transported to A Love of Humanity’s facility in the Netherlands and that cremation costs for accepted donors would be covered if requested. The consent form also stated that “the final disposition of anatomical specimens will be handled by the receiving institution in accordance with their local regulations”. It also stated that, if a donation was not accepted, responsibility for burial or cremation would rest with the executors or family members.
A Love of Humanity clarified that, once a donor’s body had fulfilled its research or educational purpose, final disposition would be arranged either by them or by the receiving institution in accordance with Dutch or local regulations. They said remains were not returned to the UK, and that family members were not required or expected to travel to the Netherlands to collect them. They said that, for accepted donors, cremation costs were covered by Fenix Biomed BV where cremation was the applicable form of final disposition. They confirmed that, where a donation was not accepted, responsibility for burial or cremation would rest with the executors or family members.
We considered that the location of the service was material because it affected how the service would operate, including the fact that remains would not be repatriated to the UK. We also considered that the circumstances in which the service would be cost-free, and the position if a donation was not accepted, were material information that consumers needed before requesting further information or registering. We noted the acknowledgement by A Love of Humanity that the website’s references to a “cost-free alternative” and “respectful and appropriate final disposition” did not explain those arrangements with sufficient clarity. We welcomed their assurance to make that information relating to the location of the company clear on the website.
However, for the reasons stated, we considered the ad at the time it was seen omitted material information about A Love of Humanity being based in the Netherlands and the practical implications of that for how the service would operate. It also gave the misleading impression that the advertiser was based in the UK. We therefore concluded that the ad was misleading.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising) and 3.9 (Qualification).
Action
The ad must not appear again in the form complained of. We told Fenix Biomed BV t/a A Love of Humanity not to imply they was based in the UK when that was not the case.
