A TV ad for Audi, seen in December 2017, promoted the Audi R8 model. The ad began with snow being sprayed towards the camera, which obscured the screen. The camera then panned out to reveal the R8 being driven in a straight line across a flat, snowy plain with a tree line visible in the background. A trail of snow was seen being expelled into the air from the moving tyres and behind the R8. On-screen text stated “The Audi R8 with snow mode. Yes, it really does have a snow mode”. As the camera continued to pan out, the ad then cut to another scene shot from an aerial angle, which showed the vehicle travelling across the snowy plain towards the direction where a number of woods were located, with a small trail visible behind the vehicle. On-screen text stated “For safety in all conditions”.
Ten complainants, who believed the ad could encourage unsafe driving practices in snow conditions, challenged whether it was irresponsible.
Volkswagen Group UK Ltd t/a Audi UK stated that the ad was intended to promote, in a visually arresting but accurate way, the safety feature designed to enhance safe and responsible driving in wintry conditions. Audi said that the Snow Mode feature was a special mode that drivers could select on the R8, which allowed for better control and adaption to the road surface, greater stability and reduced chance of oversteer (skidding) when driving in snowy, wet or dry conditions.
Audi stated that the focus of the ad was clearly safety, as the car was shown being driven at a speed suitable for the conditions depicted, whilst the closing strapline “For safety in all conditions”, which framed and set the context of the ad as a whole, left viewers in no doubt that the ad was about safe driving in all conditions. Audi commented that in order to demonstrate the efficacy of Snow Mode and the safe, precision handling of the R8, the ad had to show snow. The ad was shot in the rural location of Lake Köyry, in Rovaniemi in Finland, which was frozen with very thick and solid ice, with a covering of compressed snow, and on which it was safe to drive., They stated that they were careful to ensure that the location in which the ad was shot was prominent in the edit and bore no possible resemblance to public roads or any environment in which the R8 would actually be used by consumers. They said the location would be fantastical and other-worldly for UK consumers, as no such driving locations were likely to exist in the UK, or be familiar to UK drivers.
Audi also stated that no other cars were shown to be around in the ad, and the sky was clear with exceptionally good visibility, other than the snow on the ground. The location was entirely flat, without any uphill or downhill sections, and it was clear that there were no approaching hazards, obstacles bends or corners. A precision driver was used and was in full control of the vehicle throughout. The car was filmed driving responsibly and primarily in a straight line – it was not stunt driving – with a stopping distance far in excess of what would be required. They also said all driving took place at a controlled speed suitable for the use of Snow Mode in the relevant conditions (between 30 and 40mph depending on the particular take), so as to avoid the suggestion of excessive speed. They said that all acceleration, gear changes and deceleration were smooth and consistent, with no harsh braking or acceleration inappropriate for conditions; the driver in the ad changed up to gear quickly and all safety guidance was followed.
Audi stated that although the ‘reveal’ of the R8 at the beginning of the ad was accompanied by some engine noise, it was consistent with, or at a lower level, than other similar car ads and accurately reflected the controlled speed of the vehicle. The engine noise was then quickly reduced to background by the dominant and soothing music. They stated that the soundtrack, together with the absence of fast cutting and other similar techniques, created an overarching calm and serene tone for the ad and removed an element of aggression which accompanied conventional supercar advertising.
Audi believed the ad accurately displayed an R8 driving in Snow Mode in snowy conditions. They did not believe that the ad suggested that the Snow Mode feature enabled the vehicle to be driven fast or driven with complete safety; the vehicle was shown being driven at a speed appropriate for the driving conditions. They further stated that drivers would appreciate the risks of driving and the limitations of technology. They did not believe that there was any realistic possibility of an audience interpreting “for safety in all conditions” as a promise of 100% safety irrespective of driver behaviour or compliance with driving norms. They believed that it would be interpreted as a reference to technology providing safety benefits or greater safety.
Clearcast stated that they had reviewed ten edits with requests that Audi amend the ad each time, until finally approving the ad for broadcast. They stated that the changes to the ad that they had asked for included: the speed of the snow spray to be reduced; the trail of snow produced by the car to be slowed; for the car itself to be shown driven more sedately; and the removal of a shot of the car sliding. Other changes that Clearcast had worked on with the agency were to include more serene music and to reduce the intensity of the sound effects for the car engine and exhaust. They said they also asked for changes to some shots in order to establish that the terrain being shown was off-road, and not on a snow road. They stated that was the primary purpose of the overhead shot in one of the final scenes.
Clearcast said they had significant compliance input in the ad and were satisfied that the final version of the ad showed the R8 being driven in a context of safety and in an appropriate location. They considered that the R8 was shown as a car capable for the conditions shown and being driven in a controlled manner, off the public highway and without excessive speed. The sound effects of the car were muted, and the accompanying soundtrack provided a calm backdrop.
Clearcast stated that the handling characteristics were shown in a context of safety; the Snow Mode and the tone of the overall ad was absent of any overt excitement. They said the Snow Mode feature was not presented as a benefit that would allow reckless or unsafe driving, but was simply shown in an appropriate context, which was a deserted, snowy track. They said at no point did the ad imply that the Snow Mode would guarantee safety.
The ASA noted that, at the beginning of the ad, wind sounds and engine noise could be heard as a torrent of snow, which was obscuring the view, hit the camera. As the camera panned out swiftly, it became clear that it had been in the middle of the snow spray from the moving tyres and that it was actually a bright, clear day, with no snow falling. The camera travelled parallel to the car and showed a billowing snow trail from the rear tyres, which rose above the height of the vehicle. The sound of the engine and gear changes could still be heard in the background and the various visual and audible elements contributed to the impression that the car was being driven at high speed.
Although the car appeared to be travelling quickly, the soundtrack was a slow, a cappella version of the song ‘Sleigh ride’; the car travelled in a straight line throughout; and as the camera panned out it became clear that it was driving over a wide expanse of snow with no other vehicles nearby. We considered that viewers would also understand from the on-screen text that the focus of the ad was the Snow Mode feature, a safety feature that they might not ordinarily expect to be available on a sports car. For those reasons, we considered that the ad did not create a sense that the driving behaviour shown was risky or that Snow Mode would enable viewers to drive on public roads at speeds that they would otherwise consider were unsafe. We therefore concluded that the ad did not encourage an unsafe driving practice.
We investigated the ad under BCAP Code rules 20.1 20.1 Advertisements must not condone or encourage dangerous, competitive, inconsiderate or irresponsible driving or motorcycling. Advertisements must not suggest that driving or motorcycling safely is staid or boring. 20.3 20.3 Motoring advertisements must not demonstrate power, acceleration or handling characteristics except in a clear context of safety. Reference to those characteristics must not suggest excitement, aggression or competitiveness. and 20.5 20.5 Motoring advertisements must not exaggerate the benefit of safety features to consumers or suggest that a vehicle's features enable it to be driven or ridden faster or in complete safety. (Motoring), but did not find it in breach.
No further action necessary.