A website homepage for Harvey Water Softeners, www.harveywatersofteners.co.uk, a retailer of water softeners, seen on 29 May 2023. The page showed a picture of a water softener and stated “Save up to £1,100*”. Further down the page it stated “*across your bills, shopping, and maintenance depending on your location in the UK”. The ad contained a bullet point which stated “Reduce your bills by up to 30%”.
The complainant challenged whether the claims “Save up to £1,100” and “reduce your energy bills by up to 30%” were misleading and could be substantiated.
Harvey Water Softeners Ltd said an average family of four could generate up to 70kg of limescale per year and there were around 13 million households in the UK with hard water. They said, prior to the Covid-19 pandemic, this equated to 910,000 tonnes of limescale per year, but since the pandemic there had been a 46% rise in water usage. They provided a link to a press release by Cranfield University from March 2021 that demonstrated the increase. They said that the increase in water use had created an extra 418,600 tonnes of limescale. Based on that, they calculated that 1,328,600 tonnes of limescale had built up in hard water areas in the UK during the course of the Covid-19 pandemic.
They said the average UK household spent £33.40 a week on energy and water bills and provided a link to data from the Office for National Statistics (ONS) that showed this. They provided a paper by the UK Water Treatment Association (UKWTA) that listed a summary of studies by different organisations and universities into hard water and the treatment of it. One of these studies concluded that 0.5 mm of limescale increased fuel costs by 9.4%. Harvey Water Softeners said an average household in a hard water area would gain 1.5 mm of limescale a year, and so using a water softener could generate savings of up to 28.2% based on the estimated increase in fuel costs caused by limescale. They acknowledged that they had rounded up 28.2% to achieve the savings claim “Reduce your bills by up to 30%”, but said they would amend the claim to accurately reflect the percentage figure in future. They believed the studies cited in the UKWTA paper demonstrated that energy usage for a gas boiler, a gas water heater and an electric water heater all decreased after being descaled. The studies also showed that those appliances became less efficient when they were not descaled.Harvey Water Softeners also provided the estimated annual savings for several hard water regions in England in the event that a water softener was fitted, which were based on savings that could be made on bills, the cost of household products, including shampoo and washing up liquid, and the maintenance of household appliances.
The ad stated “Save up to £1,100” and “Reduce your bills by up to 30%” which the ASA considered consumers would understand to mean that by installing a water softener in the home, a significant proportion of people would be able to make savings of this amount and reduce their energy bills by 30%. We therefore expected the advertiser to hold evidence to demonstrate that was the case.
We noted that, in their response, Harvey Water Softeners made a number of projections based on average water consumption for a typical UK household. However, we were not provided with any evidence to substantiate these estimates, and as such, could not take them into consideration.
We then reviewed the evidence provided by Harvey Water Softeners. We first assessed the Cranfield University press release, which stated there had been a 46% increase in household water consumption. However, we were not provided with the full study which determined an increase in water consumption, and as such, we were unable to assess the methodology and results. In any case, because the increase in water usage was not used to calculate the savings claims in the ad, we considered that the press release was not directly relevant to those claims, and consequently, we did not consider it sufficient to support the claims made in the ad.
Harvey Water Softeners also provided data from the ONS that stated the average UK household spent £33.40 a week on energy and water bills. Whilst we accepted the ONS figure, it was not clear how it related to the savings claim of £1,100 in the ad, nor were we provided with further data to explain its relevance. We therefore considered that the ONS data did not substantiate the claims in the ad.
We next assessed the annual savings data following the installation of a water softener. The data showed the annual savings for several hard water regions in England, based on projected savings across bills, detergent, other household items, and the maintenance of household appliances following the installation of a water softener. However, we noted it was not clear from the data how the annual savings had been calculated and, in any case, they did not appear to be based on the experience of those in hard water areas who had reduced their expenditure following the installation of a Harvey Water softener. As such, we were not able to assess the methodology of the calculations, and considered that without that information, projected savings claims were not sufficient to substantiate the claim. Furthermore, we noted that only one city across all of the hard water regions included in the data had been projected to save £1,100, which we did not consider sufficient to substantiate the claim. For those reasons, we considered the projected savings data for the hard water regions across England were insufficient to demonstrate that consumers could save up to £1,100.
We then assessed the UKWTA paper, which summarised a list of studies that analysed the effect of limescale on certain appliances, including gas and electric water heaters and the effect of energy consumption on these appliances after being descaled. One of the studies cited in the UKWTA paper stated 0.5 mm of hard scale increased fuel costs by 9.4%. The study was published in 1949, and we considered that heating systems and other appliances were likely to be more efficient now, compared to 1949. As such, we considered that study could not be used to calculate the projected energy savings after the installation of a Harvey Water Softener product. We also considered this study summarised its findings and was not a full study. Whilst it showed that descaling had a positive effect on energy consumption in appliances, without the full methodology or results, we were unable to properly assess it. Furthermore, the study did not specifically evaluate the products that Harvey Water Softeners sold. We therefore considered that the UKWTA paper was not sufficient to demonstrate the efficacy of Harvey Water Softeners products or any subsequent energy and money savings claims.
Harvey Water Softeners stated that the average UK household in a hard water area would gain 1.5 mm of limescale a year, and as such, it could equal savings of up to 28.2%. We understood that figure was reached by multiplying the estimated increased fuel cost (9.4% per 0.5 mm of limescale) by three to calculate the amount 1.5 mm of limescale would increase fuel costs by. Because that figure was based on projections which we did not consider to be sufficiently robust we considered it could not be cited to substantiate the savings claim in the ad. In any case, we noted that the savings projections of 28.2% shared by Harvey Water Softeners were smaller than the 30% figure cited in the ad. Consequently, we considered that the evidence shared was not sufficient to substantiate the savings claim in the ad, regardless of the accuracy of the projections. We also considered the amount of limescale build-up per household would depend on individual households’ water usage, the age of the pipes and where in the UK the house was located since some areas had higher amounts of hard water than others.
Whilst a water softener was likely to provide some energy saving, we had not seen any evidence that water softeners had saved consumers up to £1,100 or reduced energy bills by up to 30%.
We therefore concluded the claims “Save up to £1,100” and “Reduce your energy bills by up to 30%” were misleading.The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation).
The ad must not appear again in its current form. We told Harvey Water Softeners Ltd to not make savings claims in the absence of adequate substantiation.