Posted: 17 July, 2024. Written by Rebecca Robbins
The Competition and Markets Authority (CMA) has today published its Consumer Law Compliance Advice for businesses relating to the marketing of green heating & insulation products (https://www.gov.uk/government/publications/marketing-green-heating-and-insulation-products/marketing-green-heating-and-insulation-products-consumer-law-compliance-advice-for-businesses).
RECC welcomes the advice and recognises that it will make an important contribution to helping all businesses understand their obligations under the law, and in building a competitive market within which consumers can make informed decisions. The advice is clear and comprehensive, and RECC supports the approach used by CMA where poor practice has been illustrated using realistic examples of marketing.
RECC also welcomes the CMA’s recognition of the important role Consumer Codes have played, and continue to play, in raising standards in this area. RECC has substantial expertise in assessing, monitoring and regulating the marketing activities of businesses offering green heating products and, crucially, the performance claims they make.
RECC has worked tirelessly to help its members understand their legal obligations regarding marketing, and to take swift action where there is evidence of misleading information in marketing materials. RECC members have access to clear, sector specific advice and training about marketing and advertising. Such information has not been more widely available to any businesses that are not RECC members.
It is important that installers and industry appreciate that this advice, and the legal obligations it covers, applies to all information provided to consumers, both in advertising and in any bespoke written or verbal claims made at the point of sale. In RECC’s experience, a poor understanding of the law in this area means it is more likely that, while installers may deploy marketing strategies that use generic and compliant claims in advertising, they will provide misleading bespoke claims directly to a consumer. For this reason, although RECC considers the CMA advice to be an important tool for business in relation to advertising, the fact that it fails to address bespoke claims is a significant omission.
RECC welcomes the CMA’s plans to look at this in more detail in the future and looks forward to working within them in the development of any similar advice.