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The Cura Team - Ezyroll Under Eye Roll-On

Recommendation: Upheld | Medium: Suo Motu - NAMS (TAMS)

The ASCI had approached the advertiser for its response in addressing the objections raised in the complaint. 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, “……whatever claims that we are making are absolutely accepted and derived from the Material Data Safety Sheet of the ingredients. ……. the documents submitted have Certificate of Analysis which have the product details - EZYROLL is mentioned in which it clearly states that the manufacturing facility has signed and approved the composition as well as manufacturing process”. As claim support data, the advertiser submitted the following documents – (1) Safety data sheet of Regu Age PF, (2) Clinical study on Regu Age PF, (3) Product approval licence, (4) Copy of product label, (5) Certificate of analysis. The advertiser then had a telecon with the ASCI Secretariat to discuss their submissions. The Consumer Complaints Council (CCC) viewed the advertisement (https://www.instagram.com/p/C9caqIivc_M/) considered the complaint and the advertiser’s response. The CCC observed that the advertiser has provided safety data sheet of the ingredient - Regu Age PF, clinical study on Regu Age PF, and certificate of analysis of the product, as claim substantiation documents. The CCC took note of the advertiser’s response that the claims made are based on the material data safety sheet of the ingredients. The CCC discussed that the advertiser is attributing the product's effectiveness in relaxing tired eyes, relaxing puffy eyes with drastic improvement in 28 days as claimed, to the presence of the ingredient – Regu Age PF contained in the product. As a result, the advertiser has made ingredient based claims for which they have not submitted any proof on the effectiveness of Regu Age PF at the levels at which it is incorporated in the product to prove the product benefits claimed. The CCC further discussed that the advertiser has not provided any product efficacy data for their formulation specific to the benefits attributable to the claimed ingredients. There is no clinical study conducted on the product as a whole to prove that the product relaxes tired eyes, puffy eyes showing improvement in 28 days. Based on these observations, the CCC concluded that the claims, “Ezyroll is a natural formulation specifically formulated to relax tired eyes after lots of screen time”, and “Relaxes puffy eyes and shows drastic improvement in 28 days”, were not substantiated with clinical evidence of product efficacy. The claims are misleading by exaggeration and are likely to lead to widespread disappointment in the minds of consumers. The source for the claims is not indicated in the advertisement. The said claims in the advertisement contravened Chapter I, Clauses 1.1, 1.2, 1.4 and 1.5 of the ASCI Code. This complaint was UPHELD.