Advertisment
Television advertising for Volkswagen (VW) Group Ireland featured footage of the Volkswagen ID3 and ID4 being driven in a rural setting. The male voiceover delivered the following information:
“In 2021 thousands of you made the Volkswagen ID3 and ID4 Ireland’s best selling all electric cars, but leadership means more to us than being number 1, it means you have trust and confidence in us to make a real difference.
Trust in us to make all electric cars with zero driving emissions and confidence with all electric cars to come, we’re helping to deliver a better future. That’s Volkswagen all electric leadership and this is just the start”.
Complaint
The complainants challenged the claim that a car could have “zero driving emissions.” They considered that while there may be no engine/tailpipe emissions, every car emitted tyre particles and brake pad particles. They outlined that while some electric vehicles (EVs) used regenerative braking which reduced brake pad particle emissions, they did not eliminate such emissions.
Response
The advertisers said that driving emissions referred specifically to emissions generated by the vehicle during road use (or driving) and acknowledged that this was a dynamic area of development and knowledge. This was, they said, even more relevant when talking about climate change and greenhouse gases, as CO2 and other engine pollutants were a major contributor to greenhouse gases globally, and reduction/elimination of these was critical for countries to hit their climate targets. This was very much the topic that dominated media and consumer conversation around the impact of the automotive sector on climate change.
The advertisers said they believed, however, that “emissions” when used in the context of automotive advertising were widely accepted and understood by consumers to refer to emissions emanating directly from the source of power of the vehicle. In combustion engine vehicles, they said, this would be commonly known as exhaust emissions (most critically Carbon Dioxide and to a lesser extent Nitrogen Oxide). BEV (Battery Electric Vehicles), also known as ZEV (Zero Emission Vehicles) in some jurisdictions, did not utilise internal combustion engines as their means of propulsion and used a battery instead which allowed for zero driving emissions (Carbon Dioxide, Nitrogen Oxide and other combustion pollutants).
They said that, as a car was operated, there could be other particles “emitted” such a paint chippings or rubber particles, depending on how the vehicle was driven, the type of road, speed, abrasion etc. However, these were not currently measured by the Worldwide Harmonised Light Vehicle Test Procedure*1 (WLTP), which was the standardised approach in the EU to measure vehicle emissions to allow consumers to make comparisons between brands and models.
Notwithstanding the information provided above the advertisers said they were dedicated to educating consumers and promoting transparency on the topic of emissions. They valued the complainants’ passion towards sustainability, and they proposed that in future communications when the term “zero driving emissions” is used that they include a disclaimer to make it clear that driving emissions refer to exhaust emissions generated during vehicle operation. This proposal would be in addition to the existing disclaimer that directs people to their website where they can learn more about their BEV products and “way to zero” strategy.
The advertisers said that it was important to note that they had not advertised their vehicles as having zero life cycle emissions but rather had used the term “zero driving emissions.” They said that while the advertising in question had now finished that going forward, they would provide the disclaimer previously mentioned in all future advertising.
*1: (https://www.wltpfacts.eu/what-is-wltp-how-will-it-work/).
Conclusion
Statement:
The Complaints Committee considered the detail of the complaint and the advertisers’ response. The Committee considered that, in line with the Code, a statement was warranted in this case.
The Committee noted that the claim ‘zero driving emissions’ was intended to refer to exhaust emissions, which were not relevant in Battery Electric Vehicles and that while the act of driving created other emissions (arising from the tyres and brakepads), these emissions were not measured by the the Worldwide Harmonised Light Vehicle Test Procedure (WLTP). While the Committee considered that consumers’ understanding of the claim would generally relate to tailpipe emissions, it was, as an unqualified claim, not correct and had the potential to mislead. Nevertheless, they noted undertaking in relation to future advertising and considered that it was appropriate that future use of the claim should be associated with an appropriate disclaimer.
ACTION REQUIRED:
Where ‘zero driving emissions’ were made, an appropriate disclaimer should be linked to the claim.
The Committee reminded advertisers generally of the need for care when using absolute terms in marketing communications.
