Background
This ruling forms part of a wider piece of work on advertising for greener heating and insulation products. The ad was identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively survey ads in specific sectors.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A regional press ad, seen in April 2025, for GGRS Energie featured an image of a building with solar panels on its roof. The headline stated, “Why 2025 is the Perfect Time to Go Solar”. A box titled “Benefits” included text that stated, “Drastically Reduced Bills: Generating your own electricity significantly reduces dependency on the grid, insulating you from rising costs”.
Issue
The ASA challenged whether:
- the claim “Drastically Reduced Bills” was misleading and could be substantiated; and
- the ad had failed to make clear all significant limitations and qualifications.
Response
1. & 2. GGRS Energie Ltd said the claim “Drastically Reduced Bills” made a general statement about the savings solar panels could facilitate. The ad had not made a comparison against other GGRS’s competitors, and that “Drastically” had been used in a colloquial sense to convey the potential for the widely recognised savings. To support the ad’s claim, they referred to a 2022 research report and a Department of Energy and Net Zero (DESNZ) press release, dated 6 June 2025. They explained, per the press release, that the basis of the ad’s claim was against a typical UK home.
GGRS acknowledged that “Drastically Reduced Bills” was open to interpretation, but did not believe the ad omitted material information. They explained the ad made a general reference to the benefit of solar panels. They said the level of saving would depend on factors such as geography, a consumer’s previous energy supply, and how their property had been built and that those points could not be addressed within the ad’s limited space. They highlighted that the ad referred to a “FREE NO OBLIGATION QUOTE” process, through which consumers would be provided with sufficient information to make an informed decision.
Assessment
1. & 2. 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 are capable of objective substantiation. It also required that price statements must not mislead by omission, and that marketing communications that include a price comparison must not mislead by failing to make the basis of the comparison clear.
The Competition and Markets Authority (CMA) guidance “Marketing green heating and insulation products: Consumer law compliance advice for businesses” (the CMA Guidance) stated that words and statements that oversell the potential benefits of a product should be avoided and that ads should not suggest certainty of an outcome if a consumer might not achieve the claimed benefit or if it was dependent on other conditions being met. The guidance also stated that important qualifying information should be presented clearly and prominently, as close to the claim as possible, such that it could not be overlooked. The ASA had regard to the guidance in assessing whether the ad had complied with the CAP Code.
We considered consumers would understand the claim “Drastically Reduced Bills” to mean installing solar panels with GGRS would result in a significant reduction to their energy bills. We therefore expected to see objective evidence that substantiated the savings claim within that context.
We assessed the sources that GGRS referred to. The 2022 research report outlined the financial benefits of installing a solar energy system. It included estimated annual running cost savings using a modifiable financial model. The report outlined four case studies with the property type and location varying between them, they included: a terraced house in the midlands, a detached house in southwest England, a semi-detached house in northeast Scotland, and a terraced house in London. The report measured the estimated annual running cost savings over 30 years and ranged between £188 and £963. The DESNZ press release outlined that savings of approximately £530 could be achieved after installing rooftop solar panels. That savings figure had been based on data from the government’s Home Energy Assessment tool. The tool, which assumed consumers had a typical 3.5 kilowatt (kW) south-facing installation per the Standard Assessment Procedure (SAP) methodology, allowed users to produce an estimate of their energy bill savings after having solar panels installed given the characteristics of their home.
Both the 2022 research report and the press release were based on estimates and outlined that the rate of savings that consumers could achieve varied and depended on their individual circumstances, including in relation to the type, size, configuration, location, and cost of their solar panel package and their overall energy usage. Due to the rate of savings outlined in both sources varying and depending on a consumer’s circumstances, it meant that not all consumers would necessarily achieve a ‘drastic’ reduction in their energy bill. Plus, we had not seen evidence that GGRS’s customers had achieved a significant reduction to their energy bills. Further, the press release post-dated the publication of the ad. As a result of these points, we considered neither the research report nor the press release were adequate forms of substantiation for the claim “Drastically Reduced Bills”.
We acknowledged GGRS’s explanation that geography, a consumer’s previous energy supply and how their property had been built, were factors that could impact the amount of money a consumer could save on their energy bills by having solar panels installed. However, the ad did not refer to those or other points that could impact the amount of money a consumer may save on their energy bills. Further, we acknowledged that the ad stated, “FREE NO OBLIGATION QUOTE”. However, we did not consider that the basis of the savings claim was sufficiently made clear in the ad itself, nor did the ad explain how much estimated money could be saved by installing solar panels, or what factors impacted their efficacy. We considered that was material information that was likely to affect a consumers’ understanding of the ad’s overall message and was required to be stated in the ad, so that consumers could proceed further into the consumer journey of obtaining solar panels from GGRS in an informed manner. We further considered the ad was neither limited by time nor space to such an extent that the information could not be provided.
As we had not been presented with adequate substantiation for the claim “Drastically Reduced Bills” and the ad omitted material information, we therefore concluded it was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), 3.7 (Substantiation), 3.9 (Qualification), 3.11 (Exaggeration), 3.17 (Prices) and 3.38 (price comparisons).
Action
The ad must not appear again in the form investigated. We told GGRS Energie Ltd to ensure that appropriate evidence was held to support any claims at the time they were made and to ensure that such claims were not exaggerated. We also told them to ensure their ads that made bill savings claims included all material information, such as any qualifications the savings claim were dependent upon.
CAP Code (Edition 12)
3.1 3.3 3.7 3.9 3.11 3.17 3.38
