Background
Summary of Council decision:
Three issues were investigated, all of which were Upheld.
Ad description
A TV ad and YouTube ad for Select Specs, seen on 18 June 2025:
a. The TV ad started with a green background, with two overlapping white circles in the middle and two pairs of glasses, and white text that stated, “2 for 1 on prescription glasses”, while a voice-over said “two for the price of one on prescription glasses? Nah. It’s 10 for the price of 1 at Select Specs” Eight more pairs of glasses appeared, and the background colour changed from green to orange, whilst the Selectspecs.com logo appeared at the bottom of the screen, which featured an orange crescent and full stop in “.com”.
Small text appeared on screen that stated, “To +/-6 sph. Minimum order £12. Free delivery over £49” and the voice-over continued, “That’s 10 pairs of prescription glasses delivered free to your door for the price of 1 pair from the high street. But the real difference is each pair can have a different prescription, so it’s glasses for everyone. Select Specs £6 specs. Frames, prescription lenses and anti-scratch coating, all from just £6 a pair – you don’t get that on the high street. Selectspecs.com/sixpounds”. The background colour changed between blue, red and yellow, before returning to orange for the final shot, which included 10 pairs of glasses and text that stated “£6 prescription glasses selectspecs.com/sixpounds You don’t get that on the high street.”
The ad also included small text at the bottom of the screen which included the text “minimum order £12. Free delivery over £49”.
b. The video on Select Specs’ own YouTube channel, was identical to ad (a).
Issue
Specsavers Optical Group Ltd challenged whether:
- the price comparison with the high street glasses, in particular the claim “10 pairs of prescription glasses […] for the price of 1 pair from the high street” was misleading;
- the same claim was verifiable; and
- the claims “Select Specs £6 specs” and “all from just £6 a pair” were misleading.
Response
Select Specs Ltd t/a Select Specs said the ads were produced by their agency Wagon Films, and that they had no additional comments to make to Wagon Films’ comments on the ads.
1. & 2. Wagon Films said the focus of the ads was only on the prescription glasses sold by Select Specs in their budget “from £6” range.
They said bright block colours had been a staple for advertising glasses and they believed the ads did not reference or make any identifiable references to any individual retailer, or use any logo or branding that indicated a comparison against any specific high street retailer. They said the frames were presented in a white spotlight against block colour backdrops and did not feature a price comparison against an identifiable competitor, but against the “high street”.
They said the ads referred to a “2 for 1” offer, which was a common marketing tool for retailers of prescription spectacles. Those offers were a mainstay of many marketing campaigns by high street opticians and glasses retailers. They highlighted several other high street chains that offered 2 for 1 deals, besides Specsavers.
They also said the high street comparison was made up of three main retailers, including Specsavers, which together made up over two-thirds share of the high street glasses market . There was a lot of crossovers in style, materials and manufacturers used across the high street opticians, which made that comparison possible. They said they had purchased glasses from the three retailers which they believed were comparable to Select Specs’ £6 range, in terms of style, features and material used. They had made online and in-store comparisons and provided a series of images, and receipts, from the three retailers, against glasses from Select Specs’ £6 range. They had submitted photos of glasses taken in-store at the other three retailers used in the comparison. The photos showed their advertised price with basic single vision lenses supplied as standard, and they had been submitted to Clearcast as part of their approval process. The comparison pairs of glasses were purchased at high street branches, at the single pair price with no upgrades. They said they also used single-vision 1.5 index lenses, supplied as standard in the high street stores, which were equivalent to the lenses supplied by Select Specs.
Wagon Films also said they had been careful to present the “10 for the price of one” claim as the ability to purchase 10 pairs of full prescription glasses for, or less than, the substantiated cost of a pair of comparable glasses from one of the three large high street retailers used in the comparison. They said consumers could purchase different prescriptions for each pair of glasses, giving up to 10 different prescriptions, unlike most high street offers, which required both pairs in a 2- for-1 offer to contain the same prescription.
They said the “10 for the price of 1” claim was not presented as a special offer, and that on-screen qualifying text explained the prescription limitations of the basic 1.5 index lenses, and that there was a minimum order of £12 when placing an order from Select Specs. They also said the Selectspecs.com website had a free delivery policy for any order totalling over £49, and therefore a customer could purchase 10 pairs of prescription glasses from Select Specs’ £6 range for £60, including delivery.
They believed their research substantiated their claims and the ads were unlikely to mislead. They also said they believed the ads included all relevant pricing, limitations and availability information.
In relation to ad (a), Clearcast said that Wagon Films had submitted data substantiating that prescription glasses of equal quality and of similar style to the £6 range from Select Specs were available from at least three high street brands, including a copy of a receipt from each brand showing a price of more than £60. They explained the comparison did not take into account 2-for- 1 offers because those brands did not permit the second pair to be of a different prescription, whereas Select Specs did.
Clearcast also said that the claim could easily be self-verified by the consumer and therefore no signposting in the ad to verification information was necessary.
3. Wagon Films said the ad claimed “all from just £6-a-pair” when explicitly referring to a full prescription glasses package of frames, prescription lenses and an anti-scratch coating. They said Select Specs had substantiated many times, over the eight years they had been advertising on TV, that every pair of Select Specs £6 specs came with frames, lenses and an anti-scratch coating. Those were indisputable facts, presented to the consumer clearly and directly.
In relation to ad (a) Clearcast said Select Specs had told them that they offered 145 styles in their £6 range.
Assessment
1. Upheld
The ASA first considered whether consumers would understand the comparison in the ads to be with Specsavers, or to a range of high street retailers. The ads began with two overlapping spotlights on a green background. The Specsavers logo was a similar shade of green, with two overlapping ovals, often with the word “Specsavers”, in white. Due to the similarity of the colours and shapes used for the Specsavers’ logo, alongside the reference to the well-known Specsavers’ 2-for-1 offer, we considered that consumers would have immediately understood the comparison in the ads to be with Specsavers. Furthermore, the ads did not refer, either explicitly or implicitly, to any other high-street retailers.
The ads stated, “That’s 10 pairs of prescription glasses […] for the price of 1 pair from the high street”, and we considered that consumers would have understood that for the cost of purchasing 10 pairs of Select Specs prescription glasses, they would only be able to purchase one pair of prescription glasses from Specsavers (or two pairs where a 2-for-1 offer applied). We considered consumers would have expected the basis of the comparison to be against Specsavers’ cheapest glasses, rather than against their range of glasses eligible for the 2-for-1 offer which we understood started at £70.
We acknowledged that it was possible to purchase 10 pairs of glasses, all with different prescriptions, from Select Specs for £60, including delivery, and we understood that the comparison in the ads was intended to be against Specsavers’ £70 range of glasses. However, Specsavers also offered a range of options starting from £15, meaning a consumer could theoretically purchase four pairs of glasses from Specsavers, also with different prescriptions for each pair, for £60. Therefore it was not the case that for the cost of 10 pairs of glasses from Select Specs, consumers could only purchase one pair from Specsavers.
For those reasons, we considered the ads, and in particular the claim “10 pairs of prescription glasses […] for the price of 1 pair from the high street”, falsely claimed a price advantage and were likely to mislead.
On that point, ad (a) breached BCAP Code rules 3.1 (Misleading Advertising), 3.34 (Comparisons with Identifiable Competitors), 3.40 and 3.41 (Price comparisons)
On that point, ad (b) breached CAP Code (Edition 12) rules 3.1 (Misleading Advertising), 3.32 (Comparisons with identifiable competitors) 3.38 and 3.39 (Price comparisons).
2. Upheld
The CAP and BCAP Codes also required that comparisons with identifiable competitors be verifiable. That meant that an ad which featured a comparison with an identifiable competitor or competitors needed to include, or direct consumers to, sufficient information to allow them to understand the comparison, and be able to check the claims were accurate, or ask someone suitably qualified to do so.
The ads included text which signposted consumers to a page of Select Specs’ website. However, that page did not include any information regarding the comparison in the ads.
Because the ads did not allow consumers to verify the comparison, we concluded that the claim that Select Specs offered “10 pairs of prescription glasses […] for the price of 1 pair from the high street” was not verifiable, and therefore breached the Code.
On that point, ad (a) breached BCAP Code rule 3.36 (Comparisons with Identifiable Competitors).
On that point, ad (b) breached CAP Code (Edition 12) rule 3.34 (Comparisons with Identifiable Competitors).
3. Upheld
We considered that consumers would understand the claims “Select Specs £6 specs” and “all from just £6 a pair” to mean they could purchase a pair of glasses from Select Specs for the price of £6.
We understood that while Select Specs did offer a range of £6 glasses, they had a minimum order requirement of £12 and free delivery was only available on orders over £49. That qualifying information was stated in small on-screen text in the ads. However, we considered that on-screen text was not sufficiently prominent to counter the overall impression given by the ads that consumers could purchase glasses for £6 from Select Specs. Furthermore, we understood that a £5.95 delivery fee would be applicable to orders below £49, which had not been stated in the ads and which was another reason why it was not possible to buy a pair of glasses from Select Specs for £6.
For those reasons, we considered that the claims “Select Specs £6 specs” and “all from just £6 a pair” were misleading .
On that point, ad (a) breached BCAP Code rules 3.1, 3.2 (Misleading Advertising) and 3.18 and 3.20 (Prices)
On that point, ad (b) breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading Advertising), 3.17 and 3.19 (Prices).
Action
The ads must not appear again in their current form. We told Select Specs Ltd t/a Select Specs to ensure that their price comparisons with competitor products did not mislead and were verifiable. We also told them to ensure their pricing claims were not misleading, including by not making sufficiently clear minimum order requirements and non-optional delivery charges.
BCAP Code
3.1 3.2 3.18 3.20 3.34 3.36 3.40 3.41
CAP Code (Edition 12)
3.1 3.3 3.17 3.19 3.32 3.34 3.38 3.39
