Ad description
The homepage of the Pet Food Expert website, petfoodexpert.com, seen in July 2025. Text under the subheading “Which food is best for my pet?” stated “Discover the facts about your pet’s food including nutritional values, allergens and even the ethics of the manufacturer. Fast, free and 100% unbiased”.
Issue
Butternut Box, who understood that Pet Food Expert was owned by Pets Corner, a pet food retailer, challenged whether the ad was misleading because it did not make clear that Pet Food Expert was owned by a competitor.
Response
Pets Corner (UK) Ltd t/a Pet Food Expert stated that Pet Food Expert was an opinion-free, fact-based site intended to allow pet owners to identify pet foods that met their needs. The site awarded each product it featured an “ingredient score”. It also provided information about the allergens each product contained and the company which sold the product. They said all the information on the website was based on product packaging, the presence of ingredients known to cause allergic reactions in pets, and company websites and social media channels. They believed that all comparisons made on the Pet Food Expert site were factual and objective, and that the scoring system used was transparent. Information about how the score awarded to each product was calculated was provided in the “How We Score” section, accessible from the top of the site’s homepage. They highlighted that the CAP Code did not apply to “natural” results on independent search engines and price comparison websites. They stated the Pet Food Expert website was an information site, and therefore believed it fell outside the scope of the CAP Code. Nevertheless, they believed the website fully complied with the Code.
Pet Food Expert said information about the ownership of the site was clearly disclosed to consumers. On the “Frequently Asked Questions” page of the website, the answer to the question “Who Created Pet Food Expert” stated that it was created by Pets Corner. They believed that disclosure was unambiguous and easily accessible to users of the site. In answer to the question “If you’re owned by Pets Corner, aren’t you biased toward your own foods?” the website stated “The Pet Food Expert has many pet food brands listed and Pets Corner only have an interest in Greenacres and More. These products are reviewed in the same way as every other product. Pet Food Expert is simply an unbiased place where pet owners can come for clarity. What they decide to buy – and where they decide to buy it from – is entirely up to them (although Pets Corner would obviously love it if pet owners chose to shop with them)”. They therefore believed that any potential concerns regarding bias were directly and prominently addressed. They said the information was presented in plain language in a location where consumers would reasonably expect to find it and could be accessed from the top of the Pet Food Expert homepage. They also provided examples of products that Pets Corner had an interest in, which received lower scores than comparative products which were not stocked by Pets Corner. They believed that if the Pet Food Expert website was biased, it would not highlight products that achieved higher scores than those in which Pets Corner had an interest.
Pet Food Expert stated that the website made no attempt to conceal the involvement of Pets Corner or suggest that Pet Food Expert was operated by an independent third party or consumer group. They believed that the commercial intent of the website, which was to provide factual information to pet owners, was transparent. They said the website did not promote Pets Corner’s products over others, or encourage consumers to purchase from Pets Corner, and instead emphasised consumer autonomy. For those reasons, they believed that should the Pet Food Expert website be considered advertising, it was fully compliant with the CAP Code.
Assessment
Upheld
The CAP Code stated that marketing communications must not falsely claim or imply that the marketer was acting as a consumer or for purposes outside its trade, business, craft or profession; they must also make clear their commercial intent, if that was not apparent from the context.
The ASA first assessed whether the Pet Food Expert website was a marketing communication for the purposes of the Code. Paragraph I(h) of the Scope of the Code stated that it applied to “advertisements and other marketing communications by or from companies, organisations or sole traders on their own websites, or in other non-paid for space online under their control, that are directly connected with the supply or transfer of goods, services, opportunities and gifts”. Paragraph II(q) stated the Code did not apply to “website content not covered by I d and I h, including (but not limited to) editorial content, news or public relations material, corporate reports and natural listings on a search engine or price comparison site”. CAP guidance on search engines and price comparison websites stated, “if a price comparison website was not independent, for example by being very closely connected to the companies it purports to compare, the entirety of the website including the ‘results’ could potentially be considered advertising”.
We understood that Pet Food Expert was owned by Pets Corner, a pet food retailer which sold many of the products listed on the Pet Food Expert website through their stores and website, and had a commercial interest in at least two of the brands featured. Pets Corner were owned by Pet Family Group Ltd, which had shareholdings in a number of pet food brands and retailers of pet related products. Pets Corner were therefore closely connected to the companies and products that Pet Food Expert purported to compare. The listings on the website included the name and image of each product, accompanied by information about the ingredients and manufacturer, and the score awarded to the product by Pet Food Expert. Each listing included a button labelled “Shop Product” which linked to the respective manufacturer’s website. We considered that any listing which showed a product ready for sale and described its features, accompanied by a “shop product” link directing the consumer to where they could purchase that product, could be regarded as a marketing communication. We therefore considered that the website was directly connected with the supply or transfer of goods, and its content did not constitute natural listings on a price comparison site. The website was therefore a marketing communication which fell within the scope of the CAP Code.
The ad stated “Discover the facts about your pet’s food including nutritional values, allergens and even the ethics of the manufacturer. Fast, free and 100% unbiased”. We considered that consumers would understand the ad to mean that Pet Food Expert was an independent, fact-based comparison site that could help them select the best food for their pet, and was not influenced by commercial interests. We considered the impression that the site was independent was reinforced by the claim “100% unbiased”, which implied to consumers that the information on the site was compiled by persons with no commercial involvement or interest in the pet food market. We therefore considered that consumers would believe the purpose of the website was to provide an independent comparison service.
However, that was not the case. Although it was used to compare products, it also had the effect of promoting products owned by Pets Corner.
We acknowledged that information about the ownership of Pet Food Expert was available on the “About” page of the website. However, we understood that the site could be navigated and used without viewing that section of the website. The “About” page of the website was therefore insufficient to alter the overall impression created by the ad that the website was independent.
Because the ad implied that Pet Food Expert was an independent food comparison site and did not make clear that it was owned by a pet food retailer, we concluded it falsely implied Pets Corner were acting for purposes outside their business and was misleading.
The ad breached CAP Code (Edition 12) rules 2.3 (Recognition of marketing communications) and 3.1 (Misleading advertising).
Action
The ad must not appear again in its current form. We told Pets Corner (UK) Ltd t/a Pet Food Expert to ensure future marketing communications did not falsely claim or imply they were acting for purposes outside their trade, for example, by presenting websites over which they had control as independent.
