Ad description

Claims on, seen in May 2013, featured the shaving brushes for sale from the advertiser.  Each listing set out the product specification and price, and a picture of the product.  A number of photos also showed the label on the product which stated "SIMPSON  MADE IN ENGLAND  STERILIZED."


The complainant challenged whether the claim "Made in England" was misleading, because he believed the products were made in the Isle of Man.


Progress Shaving Brush (Vulfix) Ltd t/a Simpson Shaving Brushes (Vulfix) stated that A. E. Simpson (manufacturers of shaving brushes and male grooming requisites) were established in England in 1919 and, in 2008, Vulfix, which was based on the Isle of Man, had taken ownership of the company.  They said the shaving brushes were manufactured on the Isle of Man and their website and invoices bore the registered address.  They stated that no attempt had been made to conceal or falsify the location of manufacture and considered there was no reason or evidence to suggest that the moniker "Made in England" was an issue.  They added that the Isle of Man and the UK Government had a VAT sharing arrangement in place because the Isle of Man was a Crown dependency.

They stated that they would deal with the matter and were developing a new website and rebranding to reflect the British origin of their products and the labels would state "Simpson Hand Made Great Britain".  They said they envisaged the changes to have taken effect by the turn of the year.



The ASA noted that it had previously received an assurance from the advertisers that their claims would be amended, but noted that they were still appearing.  We acknowledged the advertisers' repeated assurance that they would address the matter, but considered that the changes should be implemented sooner than before the end of 2013.

We acknowledged the English origins and heritage of the Simpsons brand and understood that their products had been manufactured in England in the past, but noted they were now manufactured on the Isle of Man.  We noted that, in many of the photos featuring the products, the Simpson label was visible and stated "MADE IN ENGLAND" and we considered that country of origin was an important factor for some consumers when deciding whether or not to purchase a product.  Although we acknowledged that the accompanying information about each product did not state that the product was manufactured in England, we considered that readers would nonetheless understand from the visible label that the featured product was currently manufactured in England.  Because that was not the case, we concluded that the claim "MADE IN ENGLAND" was likely to mislead.

The claims 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  3.7 3.7 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. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation).


The claims must not appear again in their current form.  We told the advertisers to ensure their advertising did not suggest their products were made in England.

CAP Code (Edition 12)

3.1     3.7    

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