Powerhouse91 - Azah Rash Free Sanitary Pads

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 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 submitted their response. The advertiser in their response stated that the claim, “3X More Absorbent”, is based on consumer product-in-use trials on female participants. Azah sanitary pads were perceived by consumers to absorb approximately three times more menstrual fluid before requiring change compared to other similar-sized pads. The claim, “100% Rash-Free”, is based on clinical dermatological testing and consumer usage trials. Clinical testing confirmed the product is non-irritant, and a study on female volunteers reported that none experienced rashes. As claim support data, the advertiser provided the following documents – (1) Product-in-use absorption study report, (2) Independent third party certification by market research agency, (3) Clinical / Dermatological Test Report, (4) Dermatologist Certification, (5) Consumer Study Report, (6) Market Research Agency Consumer Trial Certificate 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. In response the advertiser stated that it has taken necessary steps to ensure consumer safety including multiple evaluations such as consumer usage studies, dermatological safety testing as per BIS standards, and third-party research assessments. They acknowledged the concerns raised regarding the nature and scope of substantiation expected for quantitative and absolute claims. The advertiser expressed their willingness to undertake additional laboratory based testing, while requesting ASCI’s guidance on the specific nature and parameters of such testing to proceed in a timely and compliant manner. The advertiser then held a Zoom meeting with the ASCI Secretariat and the technical expert to discuss their submissions. The Consumer Complaints Council (CCC) viewed the Website advertisement, considered the complaint, the advertiser’s response along with the claim support data, and the expert’s opinion presented at the meeting. Claim – “3X more absorption*” (Disclaimer - Azah Sanitary Pads can absorb 350-400 ml, 3 times more than any other similar sized pads in the market) The CCC observed that for this claim, the advertiser submitted that it is based on a consumer product-in-use trial and not on laboratory testing. The disclaimer in the advertisement states that the claim is in comparison with other similar-sized sanitary pads and provides a quantitative measure of superiority, indicating “three times more” absorption. No laboratory test was conducted to establish that the product is 3X more absorbent. Claim – “100% Rash free Promise*” (Disclaimer - If you get skin rashes from our pads, you get your money back, no questions asked.) The CCC observed that the advertiser submitted that a test was conducted as per BIS standards, which specifies a method for evaluating the safety of cosmetic products. The test used positive and negative controls as required and was evaluated by a qualified dermatologist. The trial was not approved by an institutional ethical committee, and therefore, it cannot be termed a clinical trial under national clinical guidelines. The results showed the product had minimal reaction, with very slight skin redness or dryness and a shiny appearance in some participants, indicating the product can be considered non-irritant. The CCC further observed that although the consumer trial reported no irritation, claiming “100% Rash-Free” based only on this test may be an overstatement, as some participants experienced slight skin reactions and the test was performed on the back rather than on the area of actual use. Based on this assessment, the CCC concluded that the claims, “3X more absorption*”, and “100% Rash free Promise*”, were inadequately substantiated. The claims are misleading by exaggeration and are likely to lead to widespread disappointment in the minds of consumers. The said claims in the advertisement contravened Chapter I, Clauses 1.1, 1.4 and 1.5 of the ASCI Code. This complaint was UPHELD.