Honasa Consumer Private Limited - Mamaearth

Recommendation: Not Upheld | Medium: Industry Member

The FTCP noted the following arguments made by the complainant: In their submissions before the FTC panel, the complainant challenged the following claims made in the advertiser’s advertisement for their product – `Mamaearth Vitamin C Moisturizing Lotion Soap’ - “Nourishes like lotion”, “Moisturizing lotion soap”, and “Up to 24 Hours Moisturization”. The complainant submitted that the claims, “Nourishes like Lotion”, “Moisturizing Lotion Soap”, are not supported by any disclaimer which would indicate the scientific data, studies, result basis which such claims have been made. The claim, “Up to 24 hours moisturization”, is misleading as interaction with skin of a 76% TFM Grade 1 soap will have a greater potential of causing impaired skin barrier and skin dryness. The FTCP noted the following arguments made by the advertiser: In their submissions before the FTC panel, the advertiser submitted that they have commissioned a study on the product to evaluate the efficacy of the product. The duration of the study was 24 hours after the application of the product. During the clinical test the moisturizing effect of the product was tested by both subject self-evaluation and using a cronemeter readings and in both it was concluded that the product provided up to 24 Hours Moisturization. The FTCP Decision The FTC panel viewed the advertisement and carefully considered the submissions of both the advertiser and the complainant, and deliberated upon the matters raised. Claim – “Nourishes like lotion” The FTC panel observed that the advertiser has submitted a clinical study which was conducted to evaluate and compare the in vivo safety and efficacy in terms of moisturizing effect of skin care formulations versus untreated control on healthy human subjects. The FTC panel discussed that the product tested shows significant increase in moisturization when compared to a control or untreated area as demonstrated by the corneometry results of clinical trial report submitted. The product is claiming to provide nourishment like a lotion, however, an untreated control is used for comparison instead of the moisturizing effect of lotion. The advertiser has not provided clinical evidence of product efficacy to demonstrate that the product advertised - `Mamaearth Vitamin C Moisturizing Lotion Soap’ nourishes like lotion. Based on this assessment, the FTC panel concluded that the claim, “Nourishes like lotion”, 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 contravened Chapter I, Clauses 1.1, 1.4, and 1.5 of the ASCI Code. This complaint was UPHELD. Claim - “Moisturizing lotion soap” The FTC panel took note of the advertiser’s response that the registered name of the product is `moisturizing lotion soap’ and the same is not a claim. The advertiser has submitted regulatory formulation and ingredient list that shows that the name of the product is moisturizing lotion soap. The FTC panel discussed that the advertiser has submitted published papers on - `efficacy and benefits of sweet almond, evening primrose and jojoba oils in skin care applications’, `Glycol and Glycerin role as Solvent/co-solvent’, `Mustard Oil: Health Benefits, Nutrition, Uses and Side Effects’, `Proven Benefits of Mustard Oil for Skin’. The product contains ingredients such as mustard oil, glycerin, etc., which are known to provide moisturization to the skin. However the product does not contain lotion. The advertiser has not provided evidence to show the presence of lotion in the product that moisturizes the skin. The FTC panel further discussed that a lotion is meant to be rubbed on to the body and it is a leave on product while body soap is lathered up on a wet body and is a wash off product. The advertised product being a soap bar, the claim is likely to mislead consumers into believing that the soap moisturizes the skin as effectively as a lotion. Based on this assessment, the FTC panel concluded that the pack claim in the advertisement, “Moisturizing lotion soap”, was not substantiated. The claim is misleading by implication and exaggeration, and is likely to lead to widespread disappointment in the minds of consumers. The said claim contravened Chapter I, Clauses 1.1, 1.4, and 1.5 of the ASCI Code. This complaint was UPHELD by majority Claim – “Up to 24 Hours Moisturization” The FTC panel noted that as per the advertiser, the TFM percentage of the soap is not correlated with moisturization benefit claimed. The TFM level defines the quality, lathering, etc. of a soap. The advertiser has submitted a report of the clinical study conducted for product efficacy, the logistics of the study, and a video showing the method used for soap testing, as claim substantiation documents. The FTC panel discussed that a significant increase in capacitance shows a moisturizing effect after 24 hours of application of the product. The product also shows a significant improvement in moisturization after 24 hours on comparing the same versus untreated control. Based on the clinical evidence provided by the advertiser, the FTC panel concluded that the claim, “Up to 24 Hours Moisturization”, was substantiated. The claim is not in contravention of Chapter I of the ASCI Code. This complaint was NOT UPHELD by majority Some of the FTC panel members expressed concern that the word, “Up to” in the claim, “Up to 24 Hours Moisturization” was presented in a small font which could be missed by a lay consumer, while the words, '24 Hours moisturization' were mentioned in a large font size.