Honasa Consumer Private Limited - Anti-Acne Face Wash

Recommendation: Upheld | Medium: Industry Member

The FTC panel carefully considered the submissions of both the advertiser and the complainant, and deliberated upon the matters raised. The FTC panel observed that the advertiser has submitted a report from an in-vitro study comparing the antimicrobial efficacy of the advertiser’s product - `2% Sali-Cinamide Anti-Acne Face Wash’ with a comparator Neem Face Wash. The study aimed to evaluate how these products reduce the growth of Propionibacterium acnes (P. acnes), a bacterium linked to acne development. According to the study, the advertised product reduced bacterial growth faster than the Neem based face wash under laboratory conditions. Based on this, the advertiser claims that their product "reduces acne 3X faster than Neem face wash", with a disclaimer stating that the claim is based on an in-vitro study. The FTC panel discussed that while the product claims to reduce acne, the supporting test data only demonstrates a reduction in P. acnes, a bacterium associated with acne. However, acne is a multifactorial condition influenced by various factors including excess sebum production, inflammation, hormonal activity, diet, lifestyle, and environmental conditions. The product’s claimed benefit does not comprehensively address the broader causes of acne. Therefore, the claim of reducing acne is inadequately substantiated, as it does not consider these other contributing factors. The FTC panel further discussed that there was a lack of clarity on how the claim of 3x faster was arrived at as the study results did not demonstrate that the product performed three times faster than the neem face wash, which was evaluated in the study. As a result, the '3x faster' claim appears to be unsupported by the findings presented in the report. Based on this assessment, the FTC panel concluded that the claim, "Reduces acne 3x faster than Neem face wash”, 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. The FTC panel observed that the advertisement depicts a female model who is struggling with acne on her face. She expresses her frustration by saying, “Look at my acne. I have been using neem face wash par kuch badla hi nahin”, suggesting that despite using neem-based products, her acne has not improved. Then another female character introduces the advertised product, claiming that it reduces acne 3X faster than Neem face wash. The FTC panel discussed that there are established brands in the market offering neem face washes, known for their antibacterial properties, that are able to deliver such results. In the context of this advertisement, the portrayal of the model's dissatisfaction with the neem face wash creates an impression that neem-based products are ineffective in treating acne. By positioning the advertised product as the solution for acne while undermining the efficacy of neem face washes, the advertisement disparages the entire Neem face wash category. Based on these observations, the FTC panel concluded that the advertisement contravened Chapter IV, Clause 4.1 (e) of the ASCI Code. This complaint was UPHELD. The FTC panel observed that the claim in the advertisement states, “Reduces acne* 3X faster than Neem face wash**”. However, the accompanying disclaimers modify this claim in a way that may not be clear to the viewers. The first disclaimer mentions, “*Reduces acne causing bacteria P. acnes compared to competitor neem face wash”, and the second adds, “**Basis in-vitro data as per standard testing protocol”. The FTC panel was of the view that this discrepancy between the main claim and the disclaimer could confuse the consumers as they may interpret the claim to be about general acne reduction, while the disclaimer limits it to the reduction of acne-causing bacteria. Moreover, the disclaimer text is displayed in a font size that is too small and difficult to read. The FTC panel recommended that the disclaimers in the advertisement should be clear, distinct from the background, and prominent enough to be legible.