Hindustan Unilever Limited - Dove Serum Bar

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 claim in the advertisement, or alternately to substantiate the claim with supporting data. The advertiser was also offered an opportunity for a telecon with the ASCI Secretariat, which they availed and replied requesting for an extension of time to submit their response. The deadlines stipulated by Consumer Complaints Council (CCC) procedure exist keeping in mind the immediate and widespread impact that advertisements have on the public. Consequently, any action which is needed to be taken with respect to the same is required to be prompt and urgent. It is for this purpose that the deadlines, as stipulated, are set for advertisers/broadcasters etc, and the CCC itself makes it a priority to deal with every complaint before it as expeditiously as possible. However, as a special gesture, the advertiser was granted an extension of additional two business days to respond. The advertiser in their response stated that there is currently no formal regulatory definition for the term `serum’ and based on common understanding, a serum is generally regarded as a composition containing concentrated ingredients designed to deliver enhanced functional benefits. The claim “Enriched with Nutrient Serum” is substantiated by the presence of key ingredients in Dove bar, which collectively form a nutrient serum designed to support skin health. Regarding fragrance and allergens, the advertiser confirms that all fragrance ingredients/allergens are transparently declared on the product packaging in accordance with applicable regulatory requirements. As claim support data, the advertiser provided a copy of clinical study, Dove Serum Bar FDA License, front and back images of the product pack, and screen grab of the back of pack with the highlighted ingredients. The advertiser’s response, along with the supporting claim data, was referred to an independent ASCI technical expert for review. The expert opinion was shared with the advertiser, who then had a zoom meeting with the technical expert and the ASCI Secretariat to discuss their submissions. Following the meeting, the advertiser responded to the queries raised in the expert opinion. The advertiser stated that there is currently no cosmetic or standard definition of the term `serum’ and that the claim constitutes a monadic claim, as it does not involve any comparative assertion with other products. The Dove Serum Bar is formulated to ensure that the ingredients effectively deposit on the skin to deliver the claimed benefits. The advertiser further submitted supporting data including expert opinions, scientific references, and consumer research, for substantiation purposes. The additional submissions made by the advertiser were shared with the technical expert for final opinion. The CCC viewed the Website advertisement, considered the complaint, the advertiser’s response along with the claim support data, and the final opinion of the expert presented at the meeting. The CCC observed that the advertiser submitted supporting data to substantiate the claim, noting that there is no formal regulatory definition of `serum’ under applicable standards and that it generally refers to formulations with a high concentration of skin beneficial ingredients intended to support skin health. The advertiser stated that the product contains a blend of skin essential lipids and moisturizing ingredients and clarified that the claim relates not only to these ingredients but also to the formulation process, which is designed to be mild and deliver skin benefits during cleansing. The CCC further noted that the material submitted showed the formulation allows beneficial components from a wash-off bar to stay on the skin and support the skin barrier even after rinsing. The clinical evidence demonstrated that these ingredients can be absorbed and utilized by the skin, with contact time in the studies aligned with normal consumer washing habits. The consumer research data supported perceptions of skin softness, mildness, nourishment, and moisturization. Based on this assessment, the CCC concluded that the Website claim, “Enriched with Nutrient Serum”, was substantiated. The said claim is not in contravention of Chapter I of the ASCI Code. This complaint was NOT UPHELD.