Advertisment
A website product listing for the PanPan Smartwatch, a watch that provided access to support services.
The product specification for the watch included the following claim:
“Battery Life: up to 7 days (without location service) up to 5 days (with location service).”
Complaint
The complainant considered that the battery life claim was misleading as their watch’s battery consistently only lasted 1.5 days. They considered that the advertisement could endanger vulnerable users who relied on the device for life-critical alerts.
Response
The advertisers said that battery performance can vary depending on several environmental and usage factors, including:
• Cellular Signal Strength: Devices located far from mobile towers may consume more power due to continuous signal searching.
• Wi-Fi Availability: Limited or unstable Wi-Fi coverage can result in increased battery usage.
They said that they currently had over 3,000 units in operation across Ireland and the UK and that while some users reported shorter battery life, others regularly achieved the advertised performance. They said these variations were primarily due to the factors mentioned above and differences in individual usage patterns and environments.
In summary, they said that the advertised battery life was achievable under optimal conditions, and they remained confident that their representation reflected these parameters accurately.
By way of evidence, the advertisers provided details of a performance review they had carried out.
They said that devices under Tunstall Emergency Response’s account were supplied with location services enabled by default, given the nature of the service — supporting independent living and emergency response, so that incidents can be located and responded to promptly, however, this setting can be turned off on request. They said that their records showed that all currently active units on their account had location services enabled.
They said that when location services are enabled, the watch reports its location every 15 minutes when stationary; every 2 minutes when motion is detected; and every 22 seconds during an SOS or fall event. They said that the location was determined using Wi-Fi/cell-tower LBS and GPS.
The advertisers said that battery life varied with environment and usage;
Mobile signal quality, they said that strong coverage lets the radio (transceiver) operate at lower power, whereas poor coverage increased consumption significantly.
Location activity, they said that the frequency of location reports and use of Wi-Fi/LBS and GPS engaged different modules on the watch with different power draw.
Usage patterns: they said that SOS/fall events, screen activations, movement (more motion = more reports), and voice-call duration all affected battery life.
The advertisers said that with location services enabled in real-world use (not standby), the watch could last up to 5 days under favourable conditions, with the typical range being 2–5 days, depending on signal and usage.
With location services disabled, based on earlier lab tests and limited field observations, they said that disabling Wi-Fi, GPS and periodic wake-ups reduced average current draw by ~1.5 mA, which under good conditions corresponded to approximately two additional days of runtime and under slightly less optimal conditions corresponded to one additional day of battery life, compared with the same device and usage profile with location services enabled. They said that this typical range would be 3 – 7 days.
As evidence for the advertised claim, they said that they had reviewed 86 devices supplied in July 2025 that were active over a notified 2-week period, analysing active charging/discharging cycles over that period (21st Oct –4th Nov 2025).
They said that because users rarely discharged to 0%, partial cycles were normalised to a 100%→0% equivalent. From the aggregated cycles they noted that:
Among all devices’ lower-performing cycles, 15% reached ≥5 days.
Among all devices’ higher-performing cycles, 38% reached ≥5 days.
The average duration was 3.68 days (lower-performing cycle) and 4.67 days (higher-performing cycle). The maximum observed cycle was 8 days (extreme).
They provided the Executive with two anonymised samples of customers:
Example A (Person A, last cycle): Battery level dropped from 100% at 30th October 2025, 11:00 to 28% at 3rd November 2025, 09:00 (local time). They said that this was 72% battery consumption over 3 days 22 hours (3.9167 days), with a proportional full-cycle equivalent: 3.9167 ÷ 0.72 = ~5.44 days
Example B (Person B, last cycle): Battery level dropped from 96% at 31st October 2025, 18:00 to 35% at 4th November 2025, 06:00 (local time). They said that this was 61% battery consumption over 3 days 12 hours (3.5 days) with a proportional full-cycle equivalent: 3.5 ÷ 0.61 = ~5.74 days.
Based on the analysis, they believed it was correct to state that PanPan’s battery life could last up to 5 days (with location services enabled). While the actual results varied with signal quality and usage, they said that they would keep monitoring performance and were happy to share more detail on the methodology or help adjust settings to optimise the battery life
The advertisers subsequently advised that all references to battery life had been removed from the advertising.
Conclusion
Conclusion: Complaint Upheld.
The Complaints Council considered the detail of the complaint and the advertisers’ response.
The Council noted the results of a review carried out on 86 devices provided as evidence for the claim (accounting for 3% of units in operation) and that of the 86, 46 (53% of reviewed devices) had a battery life of greater than or equal to 5 days. The Council noted the requirements of the Code that marketing communication 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 4.09).
In this case, the Council, while noting that the claim was an ‘up to’ claim and was based on optimal conditions, considered that a reasonable expectation was that the device’s battery life would be close to 5 days, not the frequent 1.5 days experienced by the complainant. Given that the evidence provided only accounted for 3% of devices in operation and of that 3%, only 46 devices had a battery life of greater than, or equal to, 5 days, the Council did not consider that the claim had been substantiated. In the circumstances, they considered the advertising at the time of the complaint was in breach of Sections 4.1, 4.4, 4.9 and 4.10 of the Code.
Action Required:
The Council noted the advertising had been amended to remove reference to battery life.
The Council reminded advertisers to ensure that they hold robust evidence for claims made in advertising.
