ASA Adjudication on Desert Point Ltd

The website for an e-cigarette company indicated that e-cigarettes had been advertised on various news sources, such as the BBC. The ad also included the claim “Smoke Anywhere” and a “Quality Assurance” statement. The Advertising Standards Authority (ASA) found that the ad was misleading because (1) the company didn’t explain the context for the news sources’ supposed endorsement of e-cigarettes; (2) contrary to the ad’s claim, it is not always possible to use e-cigarettes; and (3) the claim about “Quality Assurance” might lead people to believe that e-cigarettes are approved and regulated, which they are not. The ASA ordered that the ad should not appear again in its current form.

ASA Adjudication on Desert Point Ltd, Complaint Ref: A12-199372 (2012).

  • United Kingdom
  • Oct 24, 2012
  • Advertising Standards Authority
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Parties

Plaintiff Unidentified complainant

Defendant Desert Point Ltd

Legislation Cited

Committee of Advertising Practice (CAP) Code, Rule 3.1 (Misleading Advertising)

Committee of Advertising Practice (CAP) Code, Rule 3.11 (Exaggeration)

Committee of Advertising Practice (CAP) Code, Rule 3.47 and 3.50 (Endorsements and Testimonials)

Committee of Advertising Practice (CAP) Code, Rule 3.7 (Substantiation)

Committee of Advertising Practice (CAP) Code, Rule 3.9 (Qualification)

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Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

"We acknowledged that explanatory text appeared alongside the CE, RoHS and SGS logos. However, we considered the explanatory text and the heading "QUALITY ASSURANCE - All ClearSmoke products are subjected to strict quality control and industry assessments" was ambiguous in that it could suggest ClearSmoke products had been assessed and approved. E-cigarettes were not, however, regulated by the MHRA and were not approved by them. Because the status of e-cigarettes was that they were unregulated, and because we considered that the heading "QUALITY ASSURANCE" and the text that followed, "All ClearSmoke products are subjected to strict quality control and industry assessments", in conjunction with the logos, was ambiguous and could suggest that they were approved and regulated, which was not the case, we concluded that the ad was misleading."
"We considered that the way in which the wording of the quotations had been selected went beyond simple factual statements about how e-cigarettes functioned and, instead, suggested that the authors or organisations were strongly in favour of the use of e-cigarettes as an alternative to smoking conventional cigarettes. Desert Point had not supplied the articles in full, but we understood that the full text of the Daily Mail article was titled "Boston becomes latest U.S. city to ban electronic cigarettes in the workplace and for under-18s" and began "[electronic cigarette users] insist the devices ..." before it continued in the way quoted in the ad. We considered that the full text suggested a more cautious or questioning position on the use of e-cigarettes than the extracts used by Desert Point suggested. We did not consider that the disclaimer, which appeared some distance away from the quotations and was considerably smaller, was sufficient to correct the suggestion. Because of that, we concluded that the way in which the quotations had been used was misleading."
"Advice published on www.nhs.uk acknowledged that e-cigarettes had increased in popularity but was cautious with regard to the health risks associated with using them. It stated that the vapour was "potentially less harmful" than tobacco smoke; that e-cigarettes may be safer than conventional cigarettes but that we didn't yet know the long-term effects of the vapour on the body. The advice stated that clinical trials were in progress to test the quality, safety and effectiveness of e-cigarettes but, until they were complete, the UK Government could not give any advice on them or recommend their use. The NHS advice also contained a link to www.ash.org.uk, which also contained cautiously-worded advice regarding the health risks associated with using e-cigarettes. The claim was worded "... you can enjoy them safely, anywhere you want". We considered that suggested the use of e-cigarettes was permitted where smoking conventional cigarettes was not, such as inside public buildings, workplaces, etc. We understood, however, that, regardless of the legal position on the use of e-cigarettes compared with smoking conventional cigarettes, policy on whether the use of e-cigarettes was actually allowed varied between organisations, employers, etc. meaning that, while it might not be illegal to use e-cigarettes, it was not always allowed in all situations. We welcomed Desert Point's willingness to amend the claim but, because they had not supplied evidence that supported an unqualified safety claim and which demonstrated it was possible to use e-cigarettes in all situations, and because we did not consider the disclaimer was sufficient to correct the understanding of the claim, we concluded that the investigated claim was misleading."
"Whether the claim referred to the ClearSmoke brand or e-cigarettes generally, Desert Point had not explained the context in which the product was claimed to have been advertised or featured on the BBC, Sky News and itv1 and had not supplied evidence to substantiate the claim. Because of that, the ASA concluded that the claim was misleading."