Background
This Ruling forms part of a wider piece of work on home efficiency scheme grants, identified for investigation following intelligence gathered by the ASA. See also related rulings published on 11 December 2024.
Ad description
Two paid-for Meta ads for Impact Energy Ltd:
a. The first ad, published on 23 May 2024, included text that stated, “ATTENTION Residents of England! If you heat your home with LPG, Oil, Solid Fuel or Electric, you could be eligible for FREE Solar Panels, Insulation and more through the ECO4 scheme. Apply now to speak to one of our ECO experts”.
The ad included an image that displayed the crown logo alongside text that stated “GOV.UK” and the Impact Energy logo. Further text stated, “Do you live in an Off-Gas Property? Free Solar Panels, Heat Pump & Insulation Claim your free renewable energy package today and reduce your energy bills by up to 70% with the ECO4 Energy Saving Grant”.
Text underneath stated “If You Heat Your Home with LPG, Solid Fuel, Oil or Electric APPLY NOW! ATTENTION Homeowners, Landlords & Tenants: You can now claim your FREE Solar Panels, Heat …” and a button labelled “Apply now”.
a. The second ad, published on 1 July 2024, included text that stated, “Free Solar Panels, Insulation and Air Source Heat Pump through the ECO4 grant”.
The ad included an image that displayed the crown logo alongside text that stated, “GOV.UK” and the Impact Energy logo. Further text stated, “Free Home Energy Upgrades For Off-Gas Properties Through The ECO4 Scheme. If you rely on LPG, Solid Fuel, Oil, Electric Storage/Room Heaters to heat your home, and have an EPC of E,F or G. You could be eligible for Free Home Upgrades. Apply Now To Check Your Eligibility”.
Text underneath stated, “If you use Oil, LPG, Solid Fuel or Electric to heat your home you could be eligible for the ECO4 …” and a button labelled “Apply now”.
Issue
The ASA challenged whether the ads misleadingly implied that the advertiser was associated with or endorsed by the UK Government.
Response
Impact Energy Ltd said they considered that their use of the government logo was appropriate because the ECO4 grant was an official, government-backed initiative. They believed that it helped to convey the legitimacy and official support behind the scheme. They also said that many of their competitors also used the logo in their ads for the same grant, which reinforced their belief that this practice was acceptable.
After being contacted by the ASA, and reviewing the specific guidelines around use of government logos in ads, they had removed the ads.
Assessment
Upheld
The ASA considered that the use of the logo which featured a previous version of the crown logo used by GOV.UK, and “GOV.UK” in both ads would be interpreted by consumers to mean that Impact Energy was associated with or endorsed by the UK Government. We further considered that the presentation of the ads, such as the fonts and graphics used, was similar to that used on UK government department websites and social media accounts, and therefore added to that impression.
We understood that at the time the ads were seen, there was a government-endorsed home energy efficiency scheme available, but that Impact Energy Ltd was not specifically associated with or endorsed by the UK Government in any way.
Because the ads gave the overall impression that Impact Energy Ltd was associated with, or endorsed by the UK government, when that was not the case, we concluded that the ads were misleading.
The ads breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 3.50 (Endorsements and Testimonials).
Action
The ads must not appear again in the form complained of. We told Impact Energy Ltd to ensure their future ads did not misleadingly imply that they were associated with, or endorsed by, the UK government.
