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Advertiser: Renewell Water
Influencer: Faces by Grace
Medium: Digital Media - Social Media, Social Media (Blogger's Own Page)
ASAI Code 7th Edition: 3.3, 3.10, 4.1, 4.4, 4.9, 4.10
A story on the Influencer’s Instagram account informed her followers that she had “the guys” and “the owner” from Renewell Water into her house and they told her all she needed to know about filtered water because she “didn’t know basically how bad drinking water straight from the tap” was. She said she “didn’t realise what chemicals and minerals were in the water” and that she was “just a little bit naïve to the situation…”
The Influencer said, “let’s get into the science, have a look at the machines, see the tests in action.” She introduced viewers to the Renewell Water purification tank and explained how there was “five stages of filtration”, with the end result being “pure water coming out of the system.”
The testing process for the Influencer’s regular tap water then commenced. The testing mechanism consisted of two steel tubes hanging from a rectangular device which was plugged into a wall socket. Each tube was inserted separately into a glass. The Influencer explained how the glass featured on the left contained her “regular tap water.” This water was muddy brown in colour and when tested appeared with black floating particles, these particles became more evident when stirred with a spoon. The Influencer stated when the water was tested “it contained lead, chlorine, magnesium, calcium, so many different chemicals” that she “was unaware of…”
Viewers were then afforded the opportunity to win one of the water filtration systems over a three-month period.
The complainant said they considered the advertising to be scaremongering in nature and that it gave a false impression that tap water was unsuitable for drinking. They raised the following issues with the advertising:
The complainant queried the testing process which had taken place on the Influencer’s tap water as they believed that no information had been provided on same. They said the instrumentation used in the process gave consumers the false impression that the water was 'dirty' when in fact in their opinion, it was leaching all of the essential metals, nutrients and minerals in order to scare consumers into buying the filtration product. They said that all the drinking water in Ireland was highly regulated and was subject to ongoing monitoring by recognised accredited laboratories. They also said that it took a number of days to carry out a full drinking water suite of tests that involved the use of specialised instrumentation.
The complainant said that no testing had been conducted on the filtered water or information provided on how it compared to the tap water.
The complainant considered it to be inappropriate for an untrained person to give advice on drinking water quality without the inclusion of fact-based evidence.
The Influencer and Renewell Water failed to provide a response to the complaint.
The Complaints Committee considered the detail of the complaint and expressed concern at the failure of both parties to respond to the complaint. They reminded them that there is an onus on advertisers to ensure that their advertising is in conformity with the Code.
The Committee noted the Code required that marketing communications should not contain claims – whether direct or indirect, expressed or implied – which a consumer would be likely to regard as being objectively true unless the objective truth of the claims can be substantiated (S 4.9) and that relevant evidence should be sent without delay if requested by the ASAI and should be adequate to support both detailed claims and the overall impression created by the marketing communication. (S 4.10).
They noted that evidence to support the claims in the advertising had not been provided to the ASAI and in light of this and in the absence of a response from both parties, the Committee concluded that the advertisement was in breach of Code sections 3.10, 4.9, and 4.10 of the Code.
The advertisement should not be published in the same format again unless relevant substantiation can be provided for the claims made.