Product and pricing checklists and videos
Published 16 July 2024
Do you sell or market green heating or insulation products for people to use in their homes?
These products include, but are not limited to:
- heat pumps
- biomass boilers
- solar panels
- insulation
To help you comply with your obligations under consumer protection law, the Competition and Markets Authority has developed 2 checklists for you to follow.
Any business involved in marketing green heating and/or insulation products for UK consumers to use in their home should read these checklists.
It’s important to treat your customers fairly, especially when it comes to advertising your headline price and making claims about your products.
Headline pricing checklist
When advertising the price of your products on your website or other marketing channels (this is called a ‘headline price’), you should be able to answer ‘yes’ or agree to all the following statements:
1. Your headline price is accurate
It gives a realistic indication of what your customers are likely to pay for your product(s) and includes all mandatory fees, taxes (where applicable), charges and any other costs.
2. Your headline price is comprehensive
It includes the cost of any works and additional products that most customers will need, in order for the product to be installed and to work effectively.
3. Your headline price is honest
It accurately reflects the likely cost that customers will pay. You never use a deceptively low headline price to attract customers.
4. Your headline price is clear
You present any important assumptions or conditions on which your headline price is based clearly and prominently, so that they can be easily seen. For example, if your headline price is based on a particular size or model of a product, or a specific type of property.
5. You are careful in how you refer to government grants
Many grants have conditions attached, such as specific eligibility criteria that not everyone will meet.
You do not include a grant in your headline price if most customers are unlikely to qualify for it.
If you do include a government grant in your headline price, you clearly and prominently state next to the price that it includes a government grant, the amount, and that it is subject to eligibility criteria.
Product claims checklist
If you make claims about your products on your website or other marketing channels, you should be able to answer ‘yes’ or agree to each of the following statements:
1. Your claims are backed up by robust evidence
Any claims you make about your product, such as its efficiency or environmental benefits, or that it can save a customer money on their energy bills, are based on up-to-date evidence from credible sources.
2. Your claims are transparent
You clearly explain everything that your customers need to know in order to make informed decisions. This includes clearly and prominently presenting any important information that is likely to affect their understanding of your claims.
3. Your claims are realistic
You do not exaggerate or oversell the benefits of your products.
Your claims are based on real-world conditions and reflect what your customers are realistically likely to achieve or experience after buying your product. Any comparisons you make with other products are reasonable, fair and transparent.
4. Your claims are easy to understand – avoid jargon
You explain your products in simple terms that customers can easily understand. You avoid jargon, vague words or technical language that might confuse your customers.
Resources to help you comply with consumer protection law
For more information, including examples of potentially misleading headline pricing and product claims, visit:
- Marketing green heating and insulation products: consumer law compliance advice for businesses
- Green claims code
What happens if your business does not comply with consumer protection law
If your business doesn’t comply with consumer protection law, the CMA and other bodies (such as Trading Standards Services) may take enforcement action.
The Advertising Standards Authority (ASA) can also take action for misleading claims which appear in marketing.
If your headline pricing or product claim is found to be in breach of consumer protection law, you can be forced to make changes to your marketing or pay compensation to any consumers that may have been harmed by the breach.
What to do if you are unsure about your marketing practices
If you are in doubt about your headline pricing practices or product claims, and think you could be at risk of breaking consumer law, seek independent legal advice.
Your local Trading Standards Service may be able to offer advice.
The ASA can provide free pre-publication advice about whether non-broadcast advertising is likely to comply with the CAP Code.
If you are a member of a Chartered Trading Standards Institute-approved Consumer Code, such as HIES or RECC, they will be able to provide you with advice on complying with the relevant provisions of their respective Codes for member businesses.
This page does not set out the CMA’s view of the law exhaustively and guidance from the CMA is not legal advice.