Ad description
The website ftcdirect.com, seen in February 2023, for pellets intended to be added to a vehicle’s fuel tank, included a testimonial from “Mike Brewer, Motoring Expert and TV Presenter”. Text stated “Carbon deposits, affect all petrol & diesel engines … causing numerous performance, engine and exhaust system problems … 80-years ago, a simple, safe and completely reliable way to permanently prevent carbon deposits ... So, along with the chaps at FTC, I’m making sure motorists are told the truth. The truth about these amazing little pellets that remove hidden carbon deposits and keep engines permanently clean & efficient".
The website included customer reviews, one of which stated “I’ve used FTC in lots of cars to restore performance, restore lost fuel economy and to make sure the exhaust emissions are as low as possible for MOT emissions tests. I’ve seen an old Volvo S60 go from 50mpg to nearly 60mpg, an Audi V8 improve from 30 to 40mpg and numerous cars get smoothed out, quietened down and run like new cars again, simply by adding the FTC pellets. In my latest Audi, V6 Le Mans, the improvement in performance and economy, since adding the pellets, has been absolutely astonishing”.
Another page on the website stated “Keeping your engine permanently clean & efficient means performance, fuel economy and emissions will stay close to those of a brand-new engine. The reaction fuel catalysts cause in petrol & diesel fuels is what safely removes tough, baked-on carbon deposits from combustion chambers and from performance-critical components like fuel injectors, intake valves and O2 sensors. This is what so effectively restores lost performance, fuel economy and reduces excess emissions - as industry-standard before & after emissions test results and MOT emissions test certificates repeatedly confirm.”
Issue
The complainant challenged whether the claims that the product could restore lost performance and fuel efficiency and reduce emissions were misleading and could be substantiated.
Response
Hamilton Direct Ltd said they first produced tin-antimony pellets in 1998 and had been selling the advertised version of the product through UK national press advertising since 2017.
They said they had received no complaints from customers who had used it in any age of petrol or diesel vehicle. They said the product was used and recommended by tens of thousands of trade and retail customers worldwide. They said pellets would remove carbon deposits from any petrol or diesel engine and restore lost engine performance and fuel efficiency, and reduce raised emissions. Newer vehicles would have fewer deposits and so the effect would be less pronounced. They believed consumers would understand that the restored performance or efficiency depended on the level of deposits removed from the engine.
Hamilton Direct Ltd provided a link to the 'Worldwide Fuels Charter – gasoline and diesel fuel 2019”, a document produced by vehicle manufacturers associations. They also provided extracts from the publications 'The Handbook of Pollution from Internal Combustion Engines' and ‘Alternative Fuels and Advanced Vehicle Technologies for Improved Environmental Performance'. They also provided extracts of a lecture by Gautum Kalghatgi, an industry expert.
They said it was accepted across the industry that carbon deposits formed quickly in new vehicles and affected all types of internal combustion engine because burning petrol/diesel released carbon which built up over time. Carbon deposits were known to adversely affect engine performance, fuel efficiency, and emissions. They stated that was supported by the documentation provided. For example, the expert lecture stated “Deposits form on all internal surfaces of the engine with use. They can affect engine performance significantly … When these deposits occur, they are likely to cause poor fuel delivery and volatilization, leading to reduced engine efficiency, increased emissions, drivability problems and loss of power".
They said that FTC Pellets removed carbon deposits from engines and could restore engine performance and reduce the extra emissions the engine produced as a result of the build-up of carbon deposits. They said that, by doing this, the product would consistently produce positive results in any petrol or diesel vehicle.
They said there was accepted industry methodology to observe the results of removing carbon from internal combustion engines. First, the engine’s exhaust emissions were measured, then the cleaner or cleaning method was added, then the exhaust emissions were measured again when the cleaning process was complete.
They sent reports of tests carried out on two vehicles:An independent report by Emissions Analytics Ltd (EA) on a 2016 diesel Volkswagen Passat between 06 April 2021 and 14 April 2021 on real-world, on-road emissions testing.
Test reports from 2022 by a customer which measured engine power on a 2012 Mini Cooper automatic before and after the pellets were added to the fuel tank (after two months of real world driving).
The report on the Passat tested the vehicle’s emissions before the pellets were added to the fuel tank and then again after they had been added. The car was driven by EA for 750 miles after the pellets were added. The report concluded that fuel economy improved by 1.4% and carbon monoxide was reduced by 28%.
The report on the Mini found a 2.9% increase in corrected engine power. Hamilton Direct explained that, in the before and after power test carried out in the 2022 test on the Mini, only the top line ‘like for like’ figure of corrected engine power was compared. Engine power had increased by 2.9% and wheel power had increased. Max power and max torque had decreased.
The before and after testing compared two sets of results/data from the same vehicle, in this case the Passat and the Mini. The first test measured the baseline result during the before test. Then the second test measured the result at a given point after the product had been added. The two data sets were then compared.
They provided MOT emissions reports dated between 2016 and 2022 for 10 petrol and diesel vehicles. They said the emissions testing had been carried out as part of the MOT and the results had been sent to them by satisfied customers who represented a broad cross-section of the UK population. Hamilton Direct Ltd had not commissioned the tests and they were not typically aware the testing was taking place until they received the results. They said the results showed a reduction in emissions recorded after the pellets were added to the vehicles’ fuel tanks and that also meant that lost performance would have been restored. They considered the tests demonstrated that their product could remove deposits from any age petrol or diesel engine. They explained that the pellets removed deposits from piston crowns, cylinders, combustion chambers, intake valves, fuel injectors and sensors which allowed modern engine systems to restore/maintain all of the engine’s optimum settings.
They also provided a report from November 2015 on a product with the same tin/antimony formulation as FTC that showed reductions in emissions on seven diesel and two petrol engines following the use of a tin alloy additive, and an evaluation report from July 1998 which they said showed the benefit of tin / antimony catalyst used in lorries.
They said that internal combustion engines had not changed significantly over time and the age of the vehicle would not affect the efficacy of the product.
Assessment
Upheld
The ASA considered consumers would interpret the ad to mean that, by using the pellets, all or most vehicles powered by a petrol or diesel engine would restore lost fuel efficiency and performance under normal driving conditions, meaning more miles per litre of fuel. We considered that consumers would understand that using the pellets in all or most petrol or diesel vehicles would reduce their emissions. We considered that the claims in the ad were objective claims that required robust substantiation based on independent testing. We would therefore need to see evidence that the results of the tests provided would be applicable to all or most vehicles. We considered that the age and type of engine and car in which it was fitted, driving conditions, driving style and atmospheric conditions were all factors that were likely to affect the outcome of fuel efficiency tests when the device was used.
We noted that the test reports described the effect of the product on two different models (two individual cars) only and we did not consider that was sufficient to show that the pellets would have an effect in all or most vehicles. In addition, the 2021 test on the Passat tested emissions and fuel economy once after a relatively short driving distance and showed that some particles and emissions had increased. We did not consider it was clear from the tests how the pellets removed carbon deposits.
We acknowledged that the MOT test results showed a reduction in emissions when the earlier test was compared to the later test, but considered that Hamilton Direct Ltd would need to show that this was as a result of using the advertised product. They did not specify at what point between the tests the pellets had been added to the fuel tank or provide information on other factors that might affect emissions - for example, the fuel used, maintenance of vehicle, driving style or other modifications to the vehicle. Seven of the cars were more than 15 years old (three were more than 20 years old) and the age of one vehicle was not clear. We understood that emissions were likely to be higher on older cars and it was not clear that the results were relevant to more recent models. The test record for one of the vehicles stated that the oil temperature was below standard for the test and, for one example, it was not clear that the before and after readings related to the same car.
With regard to the 1998 and 2015 tests on a product with the same tin/antimony formulation as FTC, we understood that the product was intended to work in the same way as FTC by removing existing deposits. The advertisers did not show that the products tested were the same, or would have the same effect, as the advertised product. In the 2015 test, of the diesel vehicles tested, five were pick-up trucks with 2.5-litre engines, two were trucks with 7.5-litre engines, most were at least five years old. Of the petrol vehicles, one was a 16-year-old jeep with 1.3-litre engine, one was a 17-year-old 2.5-litre Volvo. The vehicles tested in the 1998 report dated from 1986 to 1997. It was not clear that the results were relevant to modern vehicles.
We considered that Hamilton Direct Ltd had not shown that the pellets removed carbon deposits from vehicle engines, or that their use would result in restored lost performance and fuel economy or reduced emissions for most or all cars. We therefore concluded that the ad was misleading.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 3.47 (Endorsements and testimonials).
Action
We told Hamilton Direct Ltd not to claim or imply that their product would restore lost performance and fuel economy or reduce emissions unless they held robust substantiation.
