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Advertiser: Irish Wax Seals
Medium: Internet (Company Website)
ASAI Code 7th Edition: 3.3, 3.34, 3.35, 4.1, 4.4, 4.9, 4.10.
The advertisers’ website with a .ie domain featured a green logo with a Celtic design in the centre, the company name “Irish Wax Seals” was located around the design.
Under the section titled “About Irish Wax Seals” the following information was provided:
“We’ve been hand-engraving wax seals for our customers since 2014 and our seals and sealing wax sell across Europe. Our best-selling products can now also be found on Amazon, Ebay & Etsy…”
The complainant said they purchased a custom-made wax seal from the advertisers as they believed they were buying from an Irish company. They said the cost of the item had been stated in euro and the company URL and email contact were all presented as if they belonged to an Irish company. At no point when browsing the website had the complainant been informed that the business was in the UK and that items were shipped from there. This information only came to light when the complainant received an email confirming their purchase. The complainant said they were then notified that the item purchased was delayed at customs and they were worried that they may incur tax charges to have it delivered.
The advertisers said as manufacturers of company seals/wax seals, they conducted significant business with Ireland and had supplied their products and services to Irish customers and businesses for many years. Their domain, trading name and Euro pricing was designed to make it easier for Irish customers to find and purchase their products with ease.
The advertisers said they sold products throughout Europe and the world across many website platforms, and their products were always displayed in local currency. Their UK VAT number was listed on every page and their trading address was located on their delivery returns information pages. They said that for their Irish customers extended delivery times were stated on their website and relevant customs and duties were paid in advance. There were no hidden fees and their customers had nothing extra to pay on receipt of their goods.
In conclusion the advertisers said it had never been their intention to mislead their customers and they had now taken additional steps to help customers identify them with their company name being listed more prominently in their terms and conditions alongside full contact information. Links to this information were now available on every page.
The Complaints Committee considered the detail of the complaint and the advertisers’ response.
The Committee noted the use of the .ie domain, the inclusion of “Irish” in the name and the Celtic design and considered that when the advertising was looked at as a whole that there was a strong impression created that the company was based in Ireland and from where product distribution took place. Whilst noting that the contact details had been given more prominence in the terms and conditions, the Committee did not consider that this ameliorated the general impression given. The Committee considered, therefore, that the advertising was likely to mislead consumers and to be in breach of Sections 4.1 and 4.4 of the Code.