Ad description

Two paid-for Google ads for camera products, for Park Cameras:

a. The first ad, seen on 20 June 2017, advertised the price for a Canon M3 digital camera as £329.00.

b. The second ad, seen on 26 June 2017, advertised the price for a Tamron 24-70 lens as £699.00.


Two complainants challenged whether the price claims were misleading, because it was not possible to buy the products at the advertised prices.


Park Cameras Ltd said the ads were not misleading as it was possible for consumers to receive rebates from the manufacturer on the camera products through a “cashback” promotion. They said consumers ultimately would have the opportunity to purchase the products at the advertised prices, which excluded the cashback sum.

They explained that in order to receive cashback, customers were required to register for a rebate with the manufacturer following their purchase, therefore they considered that the ads were not misleading as the cashback offer was attainable for all consumers. They said their approach was in contrast to other ads that displayed prices for which some customers were not eligible, for example where a “Trade-in bonus” is required.



The ASA considered that the average consumer would interpret that the products would be available at the price advertised in the ads, and they would not anticipate a requirement to pay more than the advertised rate with a view to receiving “cashback” later.

We acknowledged that on clicking through to the cashback scheme was made clearer. However, the headline prices displayed on the advertiser’s website also excluded the additional cashback sum that would be added to the total cost.

We considered that the advertised prices in the two google ads did not reflect the price that the consumer needed to pay in order to purchase the camera, because the price statement excluded the additional cashback sum that was required. Additionally, there was no indication in the google ads about the requirement to pay more than the advertised rate due to the cashback scheme or any qualifying statement included.

We therefore concluded that the price claims were misleading and the ads breached the Code.

The ads breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  (Misleading advertising) and  3.17 3.17 Price statements must not mislead by omission, undue emphasis or distortion. They must relate to the product featured in the marketing communication.  (Prices).


The ads must not appear again in their current form. We told Park Cameras Ltd to ensure they used accurate prices in the future that reflected the amount paid by consumers at purchase.

CAP Code (Edition 12)

3.1     3.17    

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