Guiltfree Industries Limited - Naturali Bond Repair Regimen

Recommendation: Not 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 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 did not avail and

requested for an extension of time to submit their response.

As a special gesture the advertiser was granted an extension of additional five business days to respond.

The advertiser in their response stated that the claim in the advertisement is based on product efficacy evaluation

conducted by an independent research and testing facility. The study incorporated a damage protocol designed to

create hair fibres representative of approximately 2 years of accumulated damage. The study recorded an

improvement in hair damage assessment parameters and a statistically significant increase in tensile strength. The

disclaimer accompanying the claim further clarifies that "one application" refers to a single application of the

complete routine comprising the Shampoo, Conditioner and Serum.

As claim support data, the advertiser provided an independent efficacy study report, copy of the advertisement,

copy of the product label, and copy of the product licence.

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 addressed the queries raised by the expert regarding the product claim. They provided details of the

methodology adopted for arriving at the claim.

The additional submissions made by the advertiser were shared with the technical expert for final opinion.

The Consumer Complaints Council (CCC) viewed the Website advertisement

(https://naturali.co.in/products/naturali-bond-repair-shampoo-powered-by-terabond-technologybioactives?_

pos=2&_sid=eb6a91e1e&_ss=r), considered the complaint, the advertiser’s response along with the

claim support data, and the expert’s final opinion presented at the meeting.

The CCC observed that the advertiser submitted a report of a study entitled “In Vitro Evaluation of Hair Care

Formulations with Respect to Damage Repair Effect, Tensile Strength, Manual Combing & Sensorial Attributes

on Hair Tresses”. For the study, Indian natural black hair tresses were used. The advertiser used a protocol for

inducing two years of hair damage in the hair tresses through hair brushing, bleaching and colour application,

along with heat styling. The analysis comprising Scanning Electron Microscopy (SEM) images, tensile strength,

hair breakage analysis and shine measurement was done on baseline hair before the product application, damaged

hair and damaged hair treated with the routine.

The SEM analysis shows that hair damage reduces after one application of the routine, with improvements in

tensile strength, hair breakage and hair shine as compared to damaged hair. The results do show repair of the

damaged hair at the specified time point.

The CCC further observed that the study document submitted by the advertiser stated that there was no reference

for a two-year hair damage model. The protocol was developed considering the number of hair cleansing, hair

colour and heat cycles over two years.

Based on the above assessment, the CCC concluded that the claim, “Repairs 2 years of Hair Damage in 1

Application*”, was substantiated. The said claim is not in contravention of Chapter I of the ASCI Code. This

complaint was NOT UPHELD.