LETTER TO THE FTC - RE: ADVERTISING FOR PRESTONE EXTENDED LIFE ANTIFREEZE/COOLANT

August 24, 2006
Ms. Mary K. Engle
Associate Director
Division of Advertising Practices
Federal Trade Commission
601 New Jersey Ave, N.W.
Washington D.C., 20580

Re: Advertising for Prestone Extended Life Antifreeze/Coolant

Dear Ms. Engle:

I am writing to inform you that Honeywell Products ("Honeywell") has declined to comply with the National Advertising Review Board (NARB) recommendations as expressed in NARB Panel Report #134. This case arose from a challenge filed by The Valvoline Company ("Valvoline") concerning advertising by Honeywell Consumer Products Group ("Honeywell") for its Prestone Extended Life Antifreeze/Coolant ("Prestone"). The National Advertising Division of the Council of Better Business Bureaus (NAD) found that the challenged advertising was appropriately limited to cars and light duty trucks. However, NAD found that Honeywell's claim that Prestone can be used in vehicles of "all makes, all models" was not substantiated. NAD further found that Honeywell's claim that Prestone is compatible with any antifreeze/coolant was not substantiated. Honeywell appealed both findings.

After reviewing all case materials and hearing presentations from all parties to the matter, the NARB upheld NAD's recommendations that Honeywell discontinue its claims that Prestone can be used in vehicles of "all makes, all models," and also that Honeywell discontinue its claims that Prestone can be mixed with any other antifreeze/coolant. The NARB determined that "a reasonable consumer takeaway from the `all makes, all models' claim is that Prestone meets any required specifications established by vehicle manufacturers." NARB found that the "`meets manufacturer specifications' message has not been substantiated." NARB further found that "a reasonable consumer takeaway from the challenged advertising is that Prestone will provide the protections normally afforded by an antifreeze/coolant - including protection from internal rust and corrosion - for an extended period of time (up to 150,000 miles or 5 years) when used as the only antifreeze/coolant in a vehicle or when added to the vehicle's existing extended life antifreeze/coolant." NARB determined that "Honeywell had not provided a reasonable basis in support of this message."

Regrettably, following their receipt of the NARB Panel Report, Honeywell submitted an advertiser statement indicating the company would not comply with the NARB decision. The company was given an additional 10 days to reconsider that position, but declined to do so. Consequently, I am referring the matter to the Federal Trade Commission pursuant to Section 3.6 of NAD/NARB Procedures (enclosed), which require that when an advertiser fails to comply with a decision of the NARB the issue be brought to the attention of the appropriate government agencies.

Enclosed, please find a copy of NARB's decision. We have also enclosed a copy of the case record for your consideration. We respectfully request that you review the file to determine if it presents issues that warrant a formal review by the Commission.

I thank you for your support of the industry's self-regulatory program and look forward to hearing from you. If you have any questions I can be reached by contacting the NARB offices at (212) 705- 0114.

Sincerely, Howard Bell Chair