Vasu Healthcare Private Limited - Vasu Kumkumadi Tailam
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 `Vasu Kumkumadi Tailam' is a classical Ayurvedic formulation. The product is formulated as per the Ayurvedic literature prescribed in the Schedule I of the Drugs and Cosmetics Act, 1940. The classical text explicitly states that the application of this formulation removes facial dark spots, pimples, and blemishes, thereby enhancing facial aesthetics. Furthermore, the text states that continuous application for seven days renders the face as radiant as gold.
As claim support data, the advertiser provided the following documents – (1) Copy of FDCA licence, (2) Relevant excerpts from ayurvedic literature, (3) Literature-based Safety and Efficacy report of the individual raw materials, (4) Patch test study demonstrating the skin safety of Vasu Kumkumadi Tailam, (5) Clinical study outcomes on the finished product, (6) Product label.
The advertiser’s response with the claim support data was referred to an independent technical expert of ASCI for their opinion.
The expert opinion was then shared with the advertiser to allow them to make additional submissions.
The advertiser subsequently held an online meeting with the ASCI Secretariat and the technical expert to discuss their submissions and provided additional clinical data in support of the claims made for Kumkumadi Tailam.
The additional submissions made by the advertiser were shared with the technical expert for final opinion.
The Consumer Complaints Council (CCC) viewed the Facebook advertisement
(https://www.facebook.com/ads/library/?id=1740747047296568), considered the complaint, the advertiser’s response along with the claim support data, and the expert’s final opinion presented at the meeting.
Claim - “Reverse Fine Lines & Clear Dark Patches Naturally!”
The CCC discussed that the textual indication for Kumkumadi Tailam as shared by the advertiser is that it removes facial dark spots. It does not mention reversal of fine lines. Hence, it can be used to support only “clear dark patches naturally”. The clinical study assessed changes in skin blood circulation and melanin distribution in areas of hyperpigmentation. It also assessed changes in hyperpigmentation during the study.
The CCC further discussed that the study results indicate that the formulation helped improve the skin barrier, skin circulation and facial hyperpigmentation. However, there is no mention of fine lines in the study results. The study indicates a reduction in pigmentation, but does not establish that dark patches were cleared.
The advertiser has shared a literature-based safety and efficacy report for individual ingredients. This efficacy of individual herbs cannot be attributed to a formulation.
Based on the above assessment, the CCC concluded that the claim, “Reverse Fine Lines & Clear Dark Patches Naturally!”, was inadequately substantiated. The claim is misleading by exaggeration and is likely to lead to widespread disappointment in the minds of consumers. The said claim in the advertisement contravened Chapter I, Clauses 1.1, 1.4 and 1.5 of the ASCI Code. This complaint was UPHELD.
Claim – “Processed with Sesame oil and milk, this golden oil reverses sun damage and smooths out wrinkles”
The CCC discussed that the claim, “processed with sesame oil and milk” is substantiated based on the formulation details provided by the advertiser. However, the textual indication shared by the advertiser mentions removal of dark spots and does not support reversing sun damage or smoothing out wrinkles.
The study assessed changes related to skin circulation, melanin distribution and hyperpigmentation. It did not assess reversal of sun damage or smoothing of wrinkles. The study results also do not indicate efficacy in reversing skin damage caused by sun exposure or in smoothing wrinkles.
The CCC observed that the product is a classical Ayurvedic formulation. However, the formulation declared by the advertiser and the formulation mentioned on the pack are not exactly the same as the classical formulation referred to. The use of cow milk instead of goat milk and differences in the quantities of ingredients were noted. Hence, the benefits mentioned in the classical text cannot be attributed to the modified formulation.
Based on the above assessment, the CCC concluded that the claim, “Processed with Sesame oil and milk, this golden oil reverses sun damage and smooths out wrinkles”, was inadequately substantiated. The claim is misleading by exaggeration and is likely to lead to widespread disappointment in the minds of consumers. The said claim in the advertisement contravened Chapter I, Clauses 1.1, 1.4 and 1.5 of the ASCI Code. This complaint was UPHELD.
