Haleon India Limited - Centrum

Recommendation: Not Upheld | Medium: General Public

The ASCI had approached the advertiser for its response in addressing the grievances of the complainant and forwarded the details of the complaint, verbatim, to the advertiser with a request to respond to the same. The advertiser was offered an option to seek an Informal Resolution (IR) of the complaint by modifying or withdrawing the claims in the advertisement, or alternately to substantiate the claims with supporting data. The advertiser was also offered an opportunity for a telecon with the ASCI Secretariat, which they did not avail and submitted their response. The advertiser in their response stated that, “The Impugned Advertisement, on the contrary to the allegations, actually displays and promotes a balanced lifestyle with exercise, healthy dietary habits and considering the high prevalence of vitamin /mineral deficiency amongst Indian women, a Nutraceutical which is meant to supplement diet & provide nutrients that provide benefits to physiological functioning of the body and thus helps in maintain good health. It is important to note that there is an amount of creativity used in the impugned advertisement, which is within the acceptable norms followed by all advertisers. In all the frames of the impugned advertisement where “Glow of Health” is used (verbally as well as pictorially), we have incorporated the disclaimer “Creative visualization” to take the liberty of creativity. While, neither the Impugned Advertisement nor the Product claims to enhance skin health, however, it is important to note that the Product does contain ingredients which are specifically known to support skin health”. In support of their response, the advertiser provided extracted copy of the Product approval license, Copy of product label, and the Celebrity Due Diligence Undertaking. The advertiser’s response along with the claim support data was referred to an Independent technical expert of ASCI for an opinion in the matter. The expert’s opinion was then shared with the complainant and the advertiser for making additional submissions. On receiving the expert opinion, the complainant responded that, “Merely stating that the explanations provided have substantiated the content of the advertisement is insufficient. Each claim should be individually addressed with specific references to scientific evidence or studies supporting them”. The advertiser did not submit any additional data, and also confirmed that they did not intend to seek a meeting with the technical expert. The Consumer Complaints Council (CCC) viewed the YouTube advertisement (https://www.youtube.com/watch?v=GDK4_QdGYr0) considered the complaint and the advertiser’s response. Claim – “We always want to give our best to our Multi-life. And for that, you need health inside. That’s why, Multivitamins every day” - the CCC took note of the advertiser’s response that the product - “Centrum Women” tablets is a Nutraceutical containing 23 vital nutrients to support nutritional requirement of an adult Women (18 years CONFIDENTIAL Page 35 of 66 and above) and that helps meet the recommended dietary allowance prescribed by ICMR-NIN 2020. The product falls under the category of “Nutraceutical” as per section 3(g) read with section 6(2) of the Food Safety and Standards (Health Supplements, Nutraceuticals, Food for Special Dietary Use, Food for Special Medical Purpose, and Prebiotic and Probiotic Food) Regulations, 2022. The CCC further observed that the product label bears the list of all the nutrients contained in the product along with their %RDAs, the target population (Women Adult-Moderately working) for clarity of the consumer and recommended usage as mandated under section 5 of the Food Safety and Standards (Labelling and Display) Regulations, 2020. The said product is for Women as it meets RDA prescribed by FSSAI for Women, and the percentage RDA are clearly mentioned on the product label. The CCC discussed that the advertisement encourages a balanced diet and healthy lifestyle for general health. The advertisement also shows physical activity as the important element for good health by depicting the protagonist doing housework, exercising on a treadmill, and using a laptop. To encourage good eating habits, there is a prominent display of several kinds of fruits and vegetables in the frame when the protagonist introduces the product. The disclaimer, “Not a substitute for a varied diet. Not for Medicinal Use” is also prominently shown in the same frame. The advertisement nor the product promoted claims to treat, cure, or prevent any specific disease or condition. The content and the range of nutrients present in the product are well within the regulatory frame work and the maximum content of one RDA. Claim – “Health inside, Glow Outside for today’s multi-life. Get your Glow of Health with Centrum” – the CCC discussed that the claim, "Health Inside, Glow Outside" refers to a holistic approach to achieving total health through a well-balanced diet and active lifestyle. The CCC further discussed that the advertisement emphasizes the importance of physical activity for good health by depicting the protagonist working on a treadmill and doing her normal activities at home. The advertisement also images of fruits and vegetables, which are the primary sources of micronutrients in a human diet. The term “general health" is a broad term that can be as defined in the WHO definition. The claims of "health inside" and "glow of health" are descriptive terms that do not appear to refer to any specific skin glow. The CCC then deliberated that the product contains ingredients that are specifically known to support skin health. As part of their submissions, the advertiser provided details including relevant studies on these ingredients. Claim - The ingredients in this product are known to support overall health. – the CCC discussed that the said claim is a content claim and not a product claim. The product label includes a list of the nutrients present in the product, as well as nutritional information with RDAs for women. The advertisement carries a disclaimer, "Refer pack for details". The advertiser has also provided a summary table outlining the functions of the vitamins, minerals, and plant-based ingredients found in their product. Based on these observations, the CCC did not consider the claims, “We always want to give our best to our Multi[1]life. And for that, you need health inside. That’s why, Multivitamins every day”, “Health inside, Glow Outside for today’s multi-life. Get your Glow of Health with Centrum”, and “The ingredients in this product are known to support overall health”, to be objectionable. The said claims are not in contravention of Chapter I of the ASCI Code, and ASCI Guidelines on Advertising of Foods & Beverages (F&B).. This complaint was NOT UPHELD.