Ad description
A leaflet for Fortress Energy, a retailer of voltage optimiser products, seen on 22 October 2022, included an image of a family smiling and looking at a shared electronic device, beside a picture of a Fortress Home Voltage Optimiser product. Text in the ad said, “Your neighbours are saving on energy bills. You can too!” and “Defend your home from high bills FOREVER”. Further text said, “Why Install a Fortress Home Voltage Optimiser? Lower your bills. Reduce your energy use. Protect yourself from price increases” and “UP TO 20% SAVING ON YOUR ELECTRICITY BILLS”.
Issue
The complainant challenged whether claims that the product would save on energy bills could be substantiated.
Response
Fortress Energy Solutions Ltd t/a Fortress Energy said their voltage optimiser product was manufactured by GW Energy who had made voltage optimisers since 1994. They said a number of other companies in the UK made products that used the same technology. They explained a voltage optimiser was a transformer that was installed, at a property, between the electricity meter and the fuse board. The product worked by regulating the supply voltage to the property by preventing over supply of voltage to electrical items in the house. That then made energy, carbon and financial savings.
Fortress Energy said the electricity supply in the UK to properties was 230 V but could fluctuate between 216 V and 253 V. Most electrical equipment in the UK and Europe was rated at 220 V and operated efficiently at that level. Supplying higher voltage to those items and forcing them to operate at higher voltages caused higher energy use, more heat loss and a lower life span. They provided information from GW Energy that showed the typical savings that could be made with the voltage optimiser. The savings for a number of domestic appliances and light fittings ranged from 5.2% up to 20.9%. They explained just before or at the point of installation they would carry out a survey at a property to determine a savings estimate, based on the appliances in the house and how they were used.
In support of the claim, Fortress Energy supplied a case study from Ofgem whereby a voltage optimiser device was installed at a commercial London property in 2009. The study cited analysis from Ofgem that stated after 18 months of results the product contributed to a 9.1% average reduction in electricity consumption. They further submitted a “Guide to Voltage Optimisation” by the British Electrotechnical and Allied Manufacturers Association (BEAMA). The guide explained what voltage optimisation was and how it worked, what devices it did and did not work with (those that were voltage dependent or voltage independent), the types of voltage optimisation equipment available, how to measure the results of voltage optimisation and how voltage optimisation products were installed. They also provided the “Carbon Trust Voltage Management Guide”. The document explained the principles behind voltage optimisation and its effect on reducing electricity consumption. Additionally, they provided a case study from GW Energy for a four bedroom residential property that had a voltage optimiser installed similar to the one Fortress Energy used. The study showed a 10% saving was achieved in the property after the device was installed.
GW Energy said their preferred wording was, “can reduce energy consumption of your electrical equipment up to 19 percent” which they said was factual and supported by the laws of physics. They explained that using Ohms Law any 10% reduction in voltage, for electrical equipment that was 100% voltage dependant, would reduce its power consumption by 19%.
They said they had tested typical household equipment, such as fluorescent lights, and reduced the voltage by 10%, and had seen a reduction in power consumption by 20.9%. They had chosen not to promote that statistic and used the more conservative 19% (the amount defined by the Ohm’s law calculation) and had measured this reduction with their customers who numbered some of the largest supermarkets and retail businesses.
They acknowledged the use of the 20% figure could be misleading if it was seen to apply to the overall energy bill. That was because the saving depended on the piece of equipment and how voltage dependent it was. Applying a 10% reduction in voltage to an appliance that was only 50% voltage dependent would only get half the savings. Therefore, it was the mix of appliances in the property that would determine the overall energy saving total. Nevertheless, they said if something was 100% voltage dependent then the 19% savings figure was accurate and could not be contested.
Assessment
Upheld
The CAP Code stated that, 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 were capable of objective substantiation.
The ad stated that the Fortress Home Voltage Optimiser product could reduce energy use and save consumers money on their electricity bills. The ASA therefore considered consumers would understand from the ad that Fortress Energy’s particular product could lower their energy consumption and reduce their electricity bills, specifically “up to 20%”, in a domestic setting.
We acknowledged the guidance provided by Fortress Energy from both BEAMA and the Carbon Trust, that explained voltage optimisation in some properties, could improve power quality and therefore could make energy savings. However, the guides discussed voltage optimisation in general and did not analyse the efficacy of individual products, including Fortress Energy’s product. Similarly, while the Ofgem study showed a reduction in electricity consumption using voltage optimisation, we understood the product installed at their commercial premises was not the one used by Fortress Energy.
The case study carried out by GW Energy did refer to Fortress Energy’s product and showed energy saving in a domestic setting. However, the case study did not provide any methodology about how the testing was carried out. It also did not consider how other factors, such as whether other energy saving devices had been installed or changes in the household or the occupants’ energy habits, might have impacted on how the consumer’s electricity bills were controlled. Further to that, it was a single test involving one household and the results came from GW Energy’s measurements, not independent testing, and so the process had not been verified by an independent third party. It was not, therefore, sufficiently robust to substantiate the claims that the product could save consumers money, specifically up to 20%, on their electricity bills.
We concluded that claims in the ad the Fortress Home Voltage Optimiser could save consumers money on their energy bills had not been substantiated and were, therefore, likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading Advertising), 3.7 (Substantiation) and 3.11 (Exaggeration).
Action
The ad must not appear again in its current form. We told Fortress Energy Solutions Ltd t/a Fortress Energy not to claim or imply the product could save on energy bills, including “up to 20%”, unless they held adequate evidence to support all objective claims.
