Rabiko Lifestyle Private Limited - Wishcare Hair Growth Serum Concentrate

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 a third party clinical study was conducted to assess the claims made for `WishCare Hair Growth Serum’. The study shows that the reduction in hair fall begins well within the first 4 weeks. The study also demonstrates the induction of new hair growth within 6–8 weeks. These measurements provide objective scientific evidence that the product begins to reduce hair fall and promote new hair growth within the claimed timeframes. As claim support data, the advertiser provided a copy of clinical study report, product label, copy of Ad, and product approval license. 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 shared with the advertiser to allow additional submissions. The advertiser provided a document indicating that the values for Anagen–Telogen (A-T) ratio and hair density are statistically significant. They also submitted detailed statistical analysis and signed reports, including evaluation of Hair Density and Anagen–Telogen (A/T) ratio, for review. The advertiser further addressed the queries raised by the technical expert. The advertiser then held a zoom meeting with the ASCI Secretariat and the technical expert to discuss their submissions. Following this meeting, they submitted an additional response with a supporting document addressing the expert’s queries, presenting the scientific rationale, ingredient-level evidence, and details of clinical evaluation and testing. 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://www.mywishcare.com/products/hair-growth-serum), considered the complaint, the advertiser’s response along with the claim support data, and the expert’s final opinion presented at the meeting. Claim – “Reduces Hairfall in 4 weeks” The CCC observed that the advertiser provided a third party clinical study evaluating the safety and efficacy of the product, WishCare Hair Growth Serum Concentrate. The study was conducted on a group of adult male and female participants of Indian/Asian origin, who were instructed to apply the product twice daily on bald or shaved areas. The assessment involved both instrument based evaluation and dermatological review of the subjects. The study assessed hair growth and hair fall through measurement of the Anagen–Telogen ratio. The results, reported as an average for all participants, showed improvement over the study period; however, the report did not indicate whether this improvement was statistically significant. The CCC discussed that the study also presented user feedback indicating a reduction in hair fall over time. This feedback was based on subjective assessments through questionnaires rather than objective measurements. There was no specific data provided at the 4-week time point, and no objective measurements were presented to substantiate reduction in hair fall within this duration. The CCC further deliberated that the additional statistical analysis submitted by the advertiser showed a statistically significant improvement in the Anagen–Telogen ratio over the study period, indicating improvement in hair growth and thereby reduction in hair fall. However, this analysis does not establish reduction in hair fall in 4 weeks time. Based on this assessment, the CCC concluded that the claim, “Reduces Hairfall in 4 weeks”, was inadequately substantiated. The claim is misleading by exaggeration and is likely to lead to widespread disappointment in the minds of consumers. The source and date for the claim is not mentioned in the advertisement. The said claim in the advertisement contravened Chapter I, Clauses 1.1, 1.2, 1.4 and 1.5 of the ASCI Code. This complaint was UPHELD. Claim - “New Hair Growth in 6-8 weeks” The CCC reviewed the clinical study submitted by the advertiser, which included both user feedback and objective measurements following regular application of the product. While the users reported improvement in hair growth over time, no data was available specifically for the 6–8 week period in the original report. Following a virtual meeting, the advertiser submitted additional statistical analysis, which demonstrated a significant increase in the Anagen–Telogen ratio over the study period, confirming hair growth after product application. Based on these observations, the CCC concluded that the claim, “New Hair Growth in 6-8 weeks”, was substantiated, and is not in contravention of Chapter I of the ASCI Code. This complaint was NOT UPHELD.