Looks like the rebills are going to be affected by this:
3.24
Marketing communications must not describe items as “free” if:
3.24.1
the consumer has to pay packing, packaging, handling or administration charges for the “free” product
3.24.2
the cost of response, including the price of a product that the consumer must buy to take advantage of the offer, has been increased, except where the increase results from factors that are unrelated to the cost of the promotion, or
3.24.3
the quality of the product that the consumer must buy has been reduced.
CAP and BCAP have published joint guidance on the use of “free”.
3.25
Marketers must not describe an element of a package as “free” if that element is included in the package price unless consumers are likely to regard it as an additional benefit because it has recently been added to the package without increasing its price.
3.26
Marketers must not use the term “free trial” to describe “satisfaction or your money back” offers or offers for which a non-refundable purchase is required.
This document, as far as I can see it is not however a legal list of "rules" which must be adhered to otherwise we are breaking the law. It does appear to be a document which will be used in the initial test cases against individuals in our industry.
My only question is: If we are an offshore company (e.g Panama) and run trade thus, would this enable us to avoid the possible wrath of the UK government, even though we are buying media space in the UK?
