Archive for the ‘Regulatory’ Category
Wednesday, January 18th, 2012
The Advertising Standards Authority has today banned an advert by French car maker Citroën for its DS4 model after it triggered seizures in a number of viewers who suffer from photo-sensitive epilepsy.
The TV advert which was seen on Sky, Watch, ITV, Quest and UK Gold featured scenes in rapid succession culminating in 304 alternating black and white ‘YES’ words appearing across a screen.
Nina Best, a specialist in advertising law at Browne Jacobson commented:
“Adverts must not include visual effects that are likely to affect adversely members of the audience with photo-sensitive epilepsy. Advertisers must remember that the rules are not only about the words or images included in their advertisement, but also the way they appear is subject to constraints. It is not only what you say that can hurt but the way you say it.”
Posted by Nina Best, who specialises in regulatory matters; entertainment licensing; advertising and marketing law; advice and representation on infringement of Food Safety Manufacturing Product Regulations.
Nina Best
0115 976 6529
nbest@brownejacobson.com
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Rating: 8.0/10 (1 vote cast)
Tags: advertising, advertising standards authority, advertising watchdog, Brands, citroen, nina best, photo sensitive epilepsy, Regulatory
Posted in Advertising & Marketing, Brands, Food & drink, Regulatory | No Comments »
Thursday, December 1st, 2011
This week, the application process opened for permits to advertise, or trade in the street, in the vicinity of the London Olympics. The application process is open until 29 February 2012.
Specific Regulations, which prohibit unlicensed advertising or street trading, have now been finalised. The law is wide reaching and can catch, for instance, persons given branded clothing to wear, and pre-existing advertising in the defined areas. The law is also strict – officers have extensive powers to enforce it, and directors may find themselves personally liable for their company’s actions.
It is fair to say that the wide scope of the laws in place during the London Olympics may catch some businesses by surprise. It is therefore important to plan your marketing and trading activities early, so you can still seek advice and/or acquire permits.
Further information can also be viewed at Olympics – law and practice.
Posted by Oliver Sweeney, who specialises in regulatory matters; including compliance, representation e.g. company prosecutions and public inquiries; transport issues; commercial litigation, including reputation management, contractual litigation and injunctions.
Oliver Sweeney
0115 976 6247
osweeney@brownejacobson.com
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Tags: 2012 Olympics, advertising, branding, Brands, Regulatory, Retail, trade
Posted in Advertising & Marketing, Brands, Food & drink, Regulatory, Retail | No Comments »
Friday, November 18th, 2011
Munir Yakub Patel, an administrative clerk, made legal history today after being handed a three-year prison term for bribery and ordered to serve six years concurrently for misconduct in a public office.
Patel pled guilty on October 14 this year to requesting and receiving a bribe intending to improperly perform his functions, contrary to Section 2 of the Bribery Act. Patel was charged in relation to his employment at Redbridge Magistrates Court and was the first person charged since the Act came into force.
The imposition of a prison sentence for a relatively minor instance of bribery shows very clearly that the Act will not just be used against big corporates and sends a powerful message to individuals and smaller businesses. If businesses have not yet put in place suitable procedures to ensure compliance with the Act then this case should serve as a reminder as to why they need to so. The threat of unlimited corporate fines and prison for employees is very real.
Matthew Woodford
0121 237 3965
mwoodford@brownejacobson.com
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Tags: bribery, bribery act, browne jacobson, criminal proceedings, employment, Public Sector, Regulatory
Posted in Commercial contracts, Competition, In-house Lawyers, Public Sector, Regulatory | No Comments »
Friday, November 18th, 2011
On 14 November 2011 Coronation Street became the first UK prime time show to feature product placement advertising, following a relaxation of TV product placement rules last February.
Contrary to the predicted deluge of brands to be thrust onto viewers’ screens, this first product placement in the ITV soap takes the rather mundane form of a Nationwide cash machine appearing in Dev Alahan’s corner shop. There will also be a branded swing-board outside the store.
Product placement undoubtedly offers a potentially lucrative income generation model, with Ofcom predicting that the industry could be worth up to £30m a year. Despite some who worry that product placement is essentially subliminal advertising, and may be a challenge to the traditions of British broadcasting, the safe guards such as a small letter ‘p’ shown on screen during the programme credits will be a clear warning to viewers.
At least the residents of Coronation Street can rest easy, knowing their money is no longer being held in a fictional bank.
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Rating: 9.3/10 (3 votes cast)
Tags: advertising, Brands, browne jacobson
Posted in Advertising & Marketing, Brands, Regulatory | 1 Comment »
Monday, October 31st, 2011
Councils and other “relevant authorities” will be required under the Localism Bill to adopt a code of conduct consistent with the Nolan Principles of Public Life as a result of amendments tabled by the government on 27 October.
The Bill originally placed a duty on councils to promote and maintain high standards of conduct. However there was no requirement to have a code of conduct so there was no firm mechanism to ascertain whether Council’s were meeting the standards.
The move comes following claims that there are “serious deficiencies” in the Bill if it were implemented as originally drafted. Clearly, a code of conduct is a step forward in giving some clarity as to what the high standards might be.
However, to be effective, standards will not only need to be consistent between authorities but there will also need to be suitable sanctions for breaches of them. The challenge for councils will be having a fair, lawful and proportionate process including a right of internal appeal to enforce the code.
Helene Maillet-Vioud
0115 976 6213
hmaillet-vioud@brownejacobson.com
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Tags: local authorities, Localism Bill, Nolan principles of public life, standards of conduct by councils
Posted in Local Authorities, Regulatory | No Comments »
Wednesday, October 26th, 2011
Kenneth Clarke today (26 October) set out his proposals for a ban on referral fees in the form of draft amendments to the Legal Aid Sentencing and Punishment of Offenders bill.
Clarke’s solution excludes the creation of a criminal offence but instead relies on regulation enforced by the FSA, Claims Management Regulator, Law Society and Bar Council. Rather than setting out a comprehensive regime, Clarke relies on powers to create secondary legislation and regulatory rules to bring the ban into effect.
The initial ban would be confined to claims relating to injury or death, with the Lord Chancellor empowered to extend the categories. An exception is included for payments in relation to services (eg advertising) but the Lord Chancellor may limit the sums payable to control this potential loophole.
The proposals set out by Clarke are a measured response to referral fees which, in light of the cross- party support for a ban, should have good prospects of surviving the remaining stages of this bill’s passage.
Posted by James Arrowsmith, who specialises in high value personal injury claims, extensive experience of claims relating to head injuries and serious bodily injury, psychiatric damage and injuries to children.
James Arrowsmith
0121 237 3981
jarrowsmith@brownejacobson.com
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Tags: claims management regulator, FSA, insurance, Kenneth Clarke, law society, legal aid, punishment of offenders, referral fees, regulatory rules
Posted in Insurance, Regulatory | No Comments »
Thursday, October 20th, 2011
Andy Slaughter, the Shadow Justice Secretary, yesterday put forward his proposals to abolish referral fees, as amendments to the Legal Aid, Sentencing and Punishment of Offenders bill. These include:
- criminalising referral fee arrangements, though only in relation to road traffic claims
- a criminal offence of sending electronic communications or making telephone calls to induce a person to make an injury claim
- no damages for whiplash arising from road traffic accidents with an impact speed less that 5 mph, unless the Claimant has a particular susceptibility to injury
- additional regulation of cold calling and of claims management companies by the Information Commissioner and Legal Services Ombudsman
This mirrors Jack Straw’s Motor Insurance Regulation Bill, and runs into the same difficulties. Effective enforcement of the criminal aspects will be difficult, given the Claims Management Regulator’s past experiences and the high standard of criminal proof. The whiplash proposals will give rise to evidential issues over impact speeds and vulnerability.
Posted by James Arrowsmith, who specialises in high value personal injury claims, extensive experience of claims relating to head injuries and serious bodily injury, psychiatric damage and injuries to children.
James Arrowsmith
0121 237 3981
jarrowsmith@brownejacobson.com
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Tags: andy slaughter, information commissioner, legal aid, legal services ombudsman, motor insurance regulation bill, referral fees, road traffic claims, shadow justice secretary
Posted in Insurance, Regulatory | No Comments »
Wednesday, October 19th, 2011
The advertising watchdog, The Advertising Standards Authority (ASA), has today (19 October) banned a promotional campaign by Shell UK Ltd for misleading motorists.
According to the ASA a flyer campaign by the energy giant which said customers could ‘save up to 1 litre per tank* at no extra cost’ were misleading, exaggerated and could not be substantiated because the company could not prove that at least 10% of vehicles in the UK would save one litre in every 50 litre fill up.
This judgement is a big blow to the energy giant’s latest campaign and possibly its credibility with the motorist who is already facing sky high prices at the pumps.
Shell should have carried out its tests on a statistically significant proportion of cars on the UK market – the ASA suggested 10% – before claiming all cars on the UK market would achieve the saving.
This is an important reminder to companies to ensure any claims they base their marketing campaigns around are significantly sound and scientifically robust.
Posted by Nina Best, who specialises in regulatory matters; entertainment licensing; advertising and marketing law; advice and representation on infringement of Food Safety Manufacturing Product Regulations.
Nina Best
0115 976 6529
nbest@brownejacobson.com
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Posted in Advertising & Marketing, Brands, Regulatory | No Comments »
Monday, October 10th, 2011
On 1 October 2011 a ban came in to force on the sale of tobacco products from vending machines in England. Displays of tobacco advertisements on vending machines are also banned.
A person found guilty of selling tobacco from a vending machine will face prosecution, and if convicted in the Magistrates court could be ordered to pay a fine of up to £2,500.
The ban is intended to reduce smoking among young people. This will particularly affect 11-15 year olds, who apparently regularly use vending machines as their source of cigarettes.
There is clear public support for a ban on the sale of tobacco from vending machines. However, the tobacco industry argues that vending machines could be modified to require tokens or ID cards, rather than having an outright ban. Nevertheless, you may be in the 65% of people who are in favour of a ban? ( according to a YouGov survey commissioned by ASH).
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Tags: advertising, advertising ban, ASH, Brands, browne jacobson, cigarette advertising, cigarette advertising ban, cigarette sales, Fiona Carter, health, tobacco advertising, tobacco advertising ban, tobacco industry, tobacco sales, underage smokers, underage smoking
Posted in Advertising & Marketing, Health, Regulatory | No Comments »
Monday, October 10th, 2011
A magistrates’ court clerk has become the first person to be charged with an offence under the Bribery Act 2010. Munir Patel has been charged with requesting and receiving a bribe to improperly perform his functions. It is alleged that Mr Patel agreed to influence the outcome of criminal proceedings in relation to a motoring offence, in exchange for £500. The prosecution was brought after an investigation by the Sun.
Although this first prosecution is not the Act’s dramatic debut that we had perhaps expected, it is of course necessary that if a public official is found to be corrupt, then punishment should follow. However once the regulator has completed a first prosecution under the Act, we expect them to become more confident about prosecuting more complicated business cases.
The approach of the Courts will become clearer on 14 October 2011, when Mr Patel appears before Southwark Crown Court.
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Tags: bribery, bribery act, browne jacobson, criminal proceedings, Fiona Carter, Southwark Crown Court
Posted in Regulatory | No Comments »
Friday, July 29th, 2011
Yesterday the Business Secretary Vince Cable announced proposals in relation to the first results from the Red Tape Challenge. The Government plans to scrap or simplify around 160 out of the 257 regulations reviewed in relation to retail firms.
The proposals include:
- removing the requirement of alcohol licences to sell chocolate liqueurs
- reducing the age limit to buy Christmas crackers from 16 to 12
- removing rules relating to the safety of pencils, prams and hood cords
- removing various pieces of antiquated legislation
- removing various specific burdens identified by businesses such as the requirement on retailers to notify TV Licensing about TV sales
The Governments efforts to reduce the regulatory burden should be applauded. However a lot of the changes announced are relatively minor and will have little tangible impact on many firms. This is not an invitation to businesses to be any less vigilant in their regulatory compliance.
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Rating: 10.0/10 (1 vote cast)
Tags: government, Red Tape Challenge, regulations, Retail, Vince Cable
Posted in Brands, Regulatory, Retail | No Comments »
Thursday, July 28th, 2011
The BIS Committee tasked with scrutinising the draft Groceries Code Adjudicator Bill today published its report “Time to bring in the referee?”. The report confirms the need for an Adjudicator but suggests various changes to the Bill, namely:
- the power to impose fines from the outset, as opposed to having the power only to “name and shame”
- allowing investigations to be launched following information from indirect suppliers and trade associations and not just that from direct suppliers and publicly available information
The proposals to “beef up” the legislation have been welcomed by some, including the farming community however the British Retail Consortium has expressed concerns over the costs that may be caused to retailers having to respond to anonymised complaints, and argues for strict guidance. The saga continues and it is likely to be 2013 before an Adjudicator is finally in place.
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Tags: British Retain Consortium, farming, Groceries Code Adjudicator Bill, legislation, retailers, time to bring in the referee, trade associations
Posted in Regulatory, Retail | No Comments »
Tuesday, June 28th, 2011
The EU council has given its ‘green light’ to the European Parliament after a provisional agreement on the regulation was reached last week. Parliament will vote on the regulation on 5 July 2011.
The regulation will, amongst other things, extend compulsory country of origin labelling, create new requirements in relation to allergens, vegetable oils and imitation foods, and create a new ‘mandatory nutrition declaration’.
Proposals in relation to trans fats, and the further extension of country of origin labelling have been left in the hands of the commission to assess further. To add to this the EUFIC only yesterday released a report questioning whether consumers make healthier choices as a result of nutrition information on packaging.
Businesses may therefore find themselves further amending their labelling not long after the current proposals come into effect.
If approved, businesses will have 3 years to adapt to the new rules, and then a further 2 years to apply the ‘mandatory nutrition declaration’.
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Tags: EU council, EUFIC, mandatory nutrition declaration, nutrition information, parliament
Posted in Advertising & Marketing, Brands, Food & drink, Regulatory | No Comments »
Thursday, June 9th, 2011
The E.coli outbreak that has killed 22 people and caused 2,200 to become ill actually originated in Germany. This news comes after a German authority in Hamburg wrongly blamed the cause of the outbreak on Spanish cucumbers.
The situation raises real concerns in the way the EU alerts system is used. Spain has suffered a huge loss as a result of the crisis, not only in the financial loss to its farmers but in the, potentially irreparable, damage to its reputation as a food supplier. Member states are obliged to warn the EU’s Rapid Alert System for Food and Feed when suspected contamination of food is identified. However the naming of specific countries, especially where this could turn out to be wrong, is arguably going too far.
The loss may not only be to Spain but to the EU as a whole, with Russia imposing an embargo on all EU fruit and vegetables, stating that EU health legislation does not work.
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Tags: E.coli outbreak, EU, EU health legislation, rapid alet system for food and feed, Spanish cucumbers
Posted in Food & drink, Health & Safety, Regulatory | No Comments »
Tuesday, May 24th, 2011
Almost two years after the Competition Commission published its final version of the Groceries Supply Code of Practice (GSCOP) it appears that the tiger may finally be getting some teeth. But not yet.
A Bill introducing legislation to establish the GCA (a body to adjudicate on the application of the rules) is imminent – but the cumbersome legislative process still means the GCA will not be in place until 2013.
This matters because GSCOP was actually brought into force in February 2010. The GSCOP is a means of balancing power between suppliers and the 10 largest grocers but with no enforcement authority it inevitably loses impact.
Although, some supermarkets are making a virtue of compliance others are not. Some suppliers are aware of the GSCOP, others are not. Those who comply need to be endorsed and those who do not need to see real benefits from compliance. Until the GCA is established both business and consumers await a GSCOP with bite.
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Tags: competition commission, GCA, groceries supply code of practice, GSCOP, supermarkets, suppliers, unffair levying of costs
Posted in Advertising & Marketing, Brands, Food & drink, Regulatory | No Comments »
Thursday, May 5th, 2011
Hundreds of natural herbal remedies have been banned from sale following the introduction of European Union (EU) rules aimed at protecting consumers from their potentially dangerous side effects.
The legislation puts herbal remedies on a level playing field with other medicines which are required to undergo rigorous testing prior to going to market. Up until now, herbal remedies have been able to take advantage of an exemption which allowed unlicensed herbal remedies to be sold provided certain conditions were complied with. However, the number of herbal remedies on the market has grown over time which has led to this inevitable regulation.
Manufacturers have been aware of this impending ban for some time now and have been encouraged to register their remedies. However, the expense and complexities that come with registration is likely to mean that many household names disappear from our shelves. However, those remedies that are successful in registration are potentially going to win big as the competition reduces and they receive official endorsement of their remedial qualities.
Posted by Nina Best, who specialises in regulatory matters; entertainment licensing; advertising and marketing law; advice and representation on infringement of Food Safety Manufacturing Product Regulations.
Nina Best
0115 976 6529
nbest@brownejacobson.com
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Tags: EU regulations, herbal remedies, medicines, unlicensed herbal remedies
Posted in Advertising & Marketing, Brands, Regulatory | No Comments »
Thursday, April 28th, 2011
We have reported that the ASA, with effect from March 2011, would be extending its remit to regulate marketing communications made online. This now includes statements made on marketer’s own websites.
The first such adjudication was published yesterday. The ASA has held that a claim made on the Maperton Trust’s website – that its product repelled head lice – should not be made, since the Maperton Trust did not produce the necessary evidence to support that claim.
We have already had queries from businesses concerned about this extension. Our view is that this first decision reinforces the fundamental principle that a marketer should always be able to objectively substantiate every claim before it is made. What this decision does not address are any of the particular issues arising from online marketing, such as user-generated content, and the enforcement of codes on the use of social media. However we are confident that decisions touching on these issues will not be too far away - and we will keep you posted.
Posted by Oliver Sweeney, who specialises in regulatory matters; including compliance, representation e.g. company prosecutions and public inquiries; transport issues; commercial litigation, including reputation management, contractual litigation and injunctions.
Oliver Sweeney
0115 976 6247
osweeney@brownejacobson.com
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Rating: 10.0/10 (2 votes cast)
Tags: advertising standards authority, ASA, maperton trust, marketing communications, online marcoms ruling, online marketing, online marketing regulation
Posted in Advertising & Marketing, Brands, Regulatory | No Comments »
Tuesday, April 12th, 2011
Guidance by the Crown Prosecution Service recently released on the CPS website has now recognised that when police officers and firefighters perform a heroic act, the public interest may not be served by taking forward a prosecution.
The notes outline that police officers and firefighters may breach the Health and Safety at Work Act 1974 – s.7 – by failing to take reasonable care of their own safety, however in such circumstances (and where the safety of others is not put at risk) a prosecution is now not likely to follow.
The decision will still be taken by the Senior Prosecutor in charge of the case and will be assessed on a case by case basis, but should demonstrate that heroic acts by those working for the public should be recognised and acknowledged by the CPS rather than prosecuted.
Posted by Elaine Heaney, who specialises in health & safety/criminal law ; provides advice and representation from investigation through to court proceedings in both the Magistrates and Crown Court.
Elaine Heaney
0115 976 6090
eheaney@brownejacobson.com
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Tags: CPS, firefighters, Health and Safety at Work act 1974, police officers
Posted in Health & Safety, Regulatory | No Comments »
Wednesday, April 6th, 2011
There have been reports that the 3D effect on Nintendo’s new flagship console, the 3DS, may make certain users feel sick. Nintendo are aware of this possibility, and prudently advise users to take a break after 30 minutes of gaming. The 3D can also be turned off. But we know it can be difficult for companies to regulate how their consumer products are used.
Not all retailers are offering a full refund to users who return the console for this reason. The stores are taking the line that as the individual units are not “faulty,” the goods are fit for purpose and so comply with the Sales of Goods Act 1979.
If a product is not “safe” for its foreseeable use, then we think it cannot be “fit for purpose” – but whether this applies to the 3DS will only be answered if the issue is litigated, by a consumer or by Trading Standards.
Even if the stores are right, this negative PR will undoubtedly harm the product’s sales.
Posted by Oliver Sweeney, who specialises in regulatory matters; including compliance, representation e.g. company prosecutions and public inquiries; transport issues; commercial litigation, including reputation management, contractual litigation and injunctions.
Oliver Sweeney
0115 976 6247
osweeney@brownejacobson.com
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Rating: 9.5/10 (2 votes cast)
Tags: Nintendo, Nintendo 3DS, Sales of Goods Act 1979, trading standards
Posted in Advertising & Marketing, Brands, Regulatory | No Comments »
Wednesday, March 30th, 2011
Justice Secretary, Kenneth Clarke has announced today that the Bribery Act 2010 will come into force on 1 July 2011.
Clarke tried to dispel the concerns expressed by businesses saying that ‘combating the risks of bribery is largely about common sense, not burdensome procedures’, and that he does not expect a ‘large number of prosecutions’.
The guidance clarifies that ‘bona fide hospitality’ and similar expenses on improving the image of a commercial organisation or establishing ‘cordial relations’ are not intended to be caught by the Act. Facilitation payments will continue to be caught by the Act as they are under previous bribery laws.
The guidance clarifies what is meant by “adequate procedures.” The adequacy of procedures will be considered in accordance with the risk of bribery faced by an organisation in light of its size and type, though other factors will also be relevant.
The guidance will no doubt help businesses to prepare for the Act. How it will ultimately be enforced remains to be seen.
Posted by Fiona Carter, who specialises in commercial regulation, compliance advice and investigations; is head of Browne Jacobson’s advertising and marketing team and food and drink group.
Fiona Carter
0115 976 6224
fcarter@brownejacobson.com
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Rating: 10.0/10 (1 vote cast)
Tags: bribery act 2010, bribery laws, hopitality, Kenneth Clarke
Posted in Brands, Manufacturing, Regulatory | No Comments »
