The Telegraph article may be correct.
There was a study that showed that sitting on a heated car seat increases scrotal temperatures by about 0.5°C. <
It is known that 'raised testicular temperature has a detrimental effect on mammalian spermatogenesis and the resultant spermatozoa' <
For optimal spermatogenesis to occur, testicular temperatures need to be maintained 2–4°C lower than core body temperature. <
So if somebody's scrotal temperature is an optimal 4°C below core then raising it by 0.5°C (by using a car seat warmer) probably won't affect fertility significantly. But since googled pictures of 'scrotal thermometer' do not inspire confidence in everyday use it is best to go along with a common sense advice to limit heated seat use to a minimum.