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Saturday 24th September 2022

Do R32 Cartel* manufacturers meet Advertising Standards & Laws when marketing equipment containing 🔥 flammable refrigerants?


. *ASA Advertising Standards Authority - CAP Code 
.**Marketing & Advertising Laws?

*ASA / CAP Code is to protect consumers and promote good, safe, and fair competitiveness!!

(ASA - Advertising Standards Authority, CAP - Committee of Advertising Practice)

**Marketing & Advertising law

The Consumer Protection from Unfair Trading Regulations mean you cannot mislead or harass consumers by, for example:

  • including false or deceptive messages
  • leaving out important information
  • using aggressive sales techniques

An example of 🔥 R32 cartel manufacturer advertising that does not meet
ASA - CAP Code, Advertising Laws or their Code of Ethics.

- Why the UK Supply Chain & their customers can not buy the current A1 class non-flammable R410A in small Splits? and be forced illegally & un Ethically to buy A2L class flammable 🔥 R32??
- Why A1 class non-flammable R410A in small Splits available worldwide (USA, Canada, South America, China, Middle East, Africa, non-EU community countries, South East Asia & even Japan!) ??
Example of manufacturer's Ethical Codes

Example: Correct Advertising

Consumer products clearly display possible dangers when flammable materials are incorporated into the product!

Do publishers check or ask if advertisers follow ASA/CAP guidelines?

Some General Advertising Rules (click for more)

  • 3.1 Marketing communications must not materially mislead or be likely to do so.
    e.g. withdrawing safe (non-flammable) products with basic safety requirements and forcing replacement with products that require extra operation restrictions due to extra safety requirements and not displaying the requirements.
  • 3.3 Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous, or untimely manner. 
    e.g. if some equipment in the range contains flammables (A2L or A3 class) while others do not (A1 class), then the advert or marketing info must indicate flammable or non-flammable.
  • 3.4 Material information is information that the consumer needs to make informed decisions in relation to a product. Whether the omission or presentation of material information is likely to mislead the consumer depends on the context, the medium, and, if the medium of the marketing communication is constrained by time or space, the measures that the marketer takes to make that information available to the consumer by other means.
    e.g. Sales and marketing materials do not indicate it's flammable, BUT, Installation, USER and Service manuals do.
  • 3.6 Subjective claims must not mislead the consumer; marketing communications must not imply that expressions of opinion are objective claims.
    e.g. Daikin claims that Gas regulation in Japan does not consider R32 is flammable. " Page 12 of Daikin Chemical R32 Instruction for Use and Handling"
  • For marketing communications that quote prices for advertised products, material information [for the purposes of rule 3.3] includes the main characteristics of the product.
    e.g. claiming lower cost, ignoring extra costs to meet H&S and Building Safety Regulation requirements.
Do manufacturers also comply & respect:

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H&S 2016  No.1107 - Obligations

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