Ad description
A mobile website for Matthew Wallace trading as UK Carbon Cleaning (www.carbon-cleaning.co.uk) seen on 25 September 2016, stated "ENGINE CARBON CLEANING" Benefits: Fuel saving increased MPG. Prolongs engine life. Restores performance. Reduces emissions ... Removes carbon deposits from all engine types. Restores engine performance. Prevents wear of expensive engine parts (EGR valve, DPF, spark plug, valves, injectors, etc.) Reduces intermittent acceleration cut-out and engine noise. Reduces exhaust fumes. Facilitates vehicle inspections for pollution levels (MOT test). Increases engine lifespan ...".
Issue
The complainant challenged whether the claimed effects of the product were misleading and could be substantiated.
Response
Matthew Wallace t/a UK Carbon Cleaning explained that with all combustion engines, hydrocarbons (i.e. emissions) were expelled from the engine through the exhaust system. However, not all carbon particles made it out of the engine and those that remained would build up and clog the engine, especially in and around the component parts. Initially, when that happened it would cause inefficiencies in the engine which would lead to loss in miles per gallon (MPG), power and performance, and emissions would rise because more fuel was being used for the car to perform at the same levels as an efficient engine. There would also be excessive strain on the component parts such as valves, filters and turbos, leading to a shortening of their lifespan.
They explained that the product worked by pulsing a controlled amount of hydrogen and oxygen into the engine whilst the engine was running. The oxygen increased combustion temperatures which then helped to burn away carbon deposits in the engine, whilst the hydrogen at high engine temperatures interacted with the carbon deposits to reform into hydrocarbons, which then exited through the exhaust. They said that the process of combining hydrogen and carbon into hydrocarbons by way of high temperatures was well-established science. They said that fewer carbon deposits in the engine meant that the engine's efficiency was restored as there was less restriction on the component parts. They said that logically led to lower emissions as less fuel was being used to perform the task (i.e. restored MPG) and the combustion was more complete (i.e. restored power). Fewer carbon deposits also meant less strain on the component parts of the engine, thereby increasing their lifespan.
UK Carbon Cleaning believed it was widely accepted that if a car's emissions were higher than the manufacturer's specification, the engine was running inefficiently, whereas lower emissions improved an engine's efficiency. They said it followed that if an engine was running more efficiently, it would restore fuel and power efficiency and there would be less strain on engine components, thereby reducing wear and tear and increasing the lifespan of the engine. They believed improved engine efficiency led to improved miles per gallon (MPG).
They provided a body of evidence in support of their claims, including a series of articles, papers, 'before' and 'after' photos of the inside of an engine, test reports including a set of 'before and after' test results, a university thesis, a certification document and customer testimonials.
Assessment
Upheld
The ASA considered that consumers were likely to interpret the claims to mean the product would have a noticeable benefit on engines in all the ways described in the ad and on most, if not all, types of vehicle. Therefore, we considered that, in order to substantiate the claims, UK Carbon Cleaning needed to provide evidence that showed the claimed benefits of the product were applicable to all or most vehicles.
We considered that the claims were objective claims that required robust substantiation based on independent testing, and considered that customer testimonials, articles and papers, 'before' and 'after' test results and images, a certification document and a university thesis were not sufficient to demonstrate that the claims had been substantiated.
We assessed the test reports provided. We had concerns that one test measured the effects of adding hydrogen to petrol and therefore did not represent the product (which pulsed a combination of hydrogen and oxygen into an engine whilst it was running). The test was also carried out in 1977 and was not therefore carried out on a modern-day engine. Another test measured the reaction of atomic hydrogen and carbon, at a molecular level, over a range of temperatures. That test did not, therefore, measure any of the claimed benefits of the product on car engines. Several test reports were relevant to the product and its claimed benefits. However, we had concerns that a number of the tests contained little or no explanation of methodology and it was not clear what the results were or whether they were statistically significant. In all cases, the vehicles were tested only once. We also noted that the tests had been carried out on a small selection of vehicles, the majority of which were older cars with high mileage. For example, one test had been carried out on a Toyota Celica 2.0 GT which was manufactured in 1995 and had a 178,709 mileage. We considered, therefore, that evidence was not applicable to all or most vehicles. We also noted that none of the test reports provided measured the effect of the product on wear and tear on engine parts or engine lifespan or intermittent acceleration cut-out.
Given the issues identified with the test reports, we considered that the evidence was not adequate to demonstrate that the product saved fuel and increased MPG, prolonged engine life, restored engine performance, reduced emissions, removed carbon deposits from all engine types, prevented wear of engine parts, reduced intermittent acceleration cut-out and engine noise, reduced exhaust fumes, facilitated vehicle inspections for pollution tests (MOT test) or increased engine lifespan. We therefore concluded that the claims had not been substantiated and were misleading.
The ad breached CAP Code (Edition 12) rules 3.1 3.1 Marketing communications must not materially mislead or be likely to do so. (Misleading advertising), 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) and 3.11 3.11 Marketing communications must not mislead consumers by exaggerating the capability or performance of a product. (Exaggeration).
Action
The ad must not appear again in its current form. We told UK Carbon Cleaning not to claim that their product saved fuel and increased MPG, prolonged engine life, restored engine performance, reduced emissions, removed carbon deposits from all engine types, prevented wear of engine parts, reduced intermittent acceleration cut-out and engine noise, reduced exhaust fumes, facilitated vehicle inspections for pollution tests (MOT test) or increased engine lifespan, unless they held adequate evidence to substantiate those claims.
