Honasa Consumer Private Limited - The Derma Co 20000 PPM Kojic Acid Microneedle Serum Shot

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, “It is submitted that the Product contains needles like micro spicules that improves the penetration of the product compared to other serums without such spicules. To evaluate the penetration of the product, the Company has conducted a permeation invitro study to study through a third-party lab. the Company has conducted an invitro study on the Product to assess the effective to enhance the collagen expression through a third-party lab. Furthermore, the Products contains ingredients such as vitamin C (ethyl Ascorbic Acid), which is known for their cosmetic benefits including skin brightening, glow, anti-pigmentation, etc. It is submitted that the term “glassier skin” is a commonly used puffery in the skin care industry. The term "glassier skin” means brighter and more radiant skin”. As claim support data, the advertiser provided the following documents – (1) Permeation study of Ethyl Ascorbic Acid for 50000 PPM Vitamin C Microneedle Serum Shot, (2) List of ingredients and FDA certificate, (3) Research papers on collagen production benefits of microneedling, (4) Invitro study on the product to assess the effective to enhance the collagen expression, (5) Research papers on the efficacy of Vitamin C (Ethyl Ascorbic Acid), (6) Front and back of product packaging. The advertiser’s response along with the claim support data was referred to an Independent technical expert of ASCI for an opinion in the matter. The expert’s opinion was then shared with the advertiser for making additional submissions. The advertiser addressed the queries raised in the expert’s opinion. They further submitted the following documents – (1) Research papers on `Effect of Vitamin C on melanin pigmentation’, `Benefits of Vitamin C for Skin’, `Skin collagen for overall health, appearance, and beauty’, `Efficacy of topical vitamin C in melasma and photoaging: A systematic review’, `Topical ascorbic acid on photoaged skin - double-blind study vs. placebo’, `3-O-ethyl-l-ascorbic acid: Characterisation and investigation of single solvent systems for delivery to the skin’, `Ascorbic Acid Treatments as Effective and Safe Anti-Aging Therapies for Sensitive Skin’, `Efficacy of topical vitamin C in melasma and photoaging: A systematic review’. The additional submissions made by the advertiser were sent to the technical expert for final opinion. The Consumer Complaints Council (CCC) viewed the Instagram advertisement (https://www.instagram.com/reel/DI8In7RIsqf/?igsh=OGZnbmk0OWgyYXY5), considered the complaint, the advertiser’s response along with the claim support data, and the expert’s final opinion presented at the meeting. Claim – “It’s infused with micro needles tiny invisible structures that boost absorption five times more than traditional serums [voiceover claim] / 5X Higher Penetration VS Regular serums*” The CCC observed that the advertiser has submitted data from a permeation study conducted using Ethyl Ascorbic Acid at a high concentration in a Vitamin C Microneedle Serum Shot. The data shows that the microneedle serum demonstrates five times better permeation across the skin compared to the serum without micro-needles. Additionally, a research paper has been submitted which establishes that microneedling improves penetration. While that study used a dermaroller, the current formulation involves micro-needles embedded directly in the serum, which could similarly enhance penetration. Based on this assessment, the CCC concluded that the said claims in the advertisement were substantiated. The claims are not in contravention of Chapter I of the ASCI Code. This complaint was NOT UPHELD. Claim – “It also triggers collagen production giving you glowing youthful skin without invasive treatments [voiceover claim] / Triggers collagen production = tighter, youthful skin / Increases Collagen production & reduces dark spots” The CCC observed that in support of these claims, various studies and documents have been submitted. One is a study using human dermal fibroblasts which shows that the serum increases collagen expression. Another is a research paper which confirms that Vitamin C can modulate collagen synthesis and contributes to skin radiance by acting against hyperpigmentation. However, there is a difference in concentration between the product in that study and the serum under review. The study used 30% Vitamin C along with lactic acid, whereas the serum contains only 5% Vitamin C. The CCC discussed that the further literature submitted confirms that reduced collagen and elastin levels affect skin firmness and elasticity, and that products containing antioxidants, retinoids, and peptides help minimize wrinkles and improve texture. Additional references highlight the role of collagen in skin health and describe how collagen-based products help maintain a youthful appearance. One study using Vitamin C derivatives found that such formulations can address issues like hydration, elasticity, pigmentation, and skin tone. Based on all the submitted documents and in vitro studies, it is established that the serum supports collagen production, which may contribute to tighter, youthful skin. However, the claim that it reduces dark spots or gives glowing skin was not substantiated, as there is no evidence or clinical study on the serum itself proving this effect. The CCC further discussed that the additional supporting documents submitted include a study of a commercial cream with 5% Vitamin C, which showed reduced signs of photo-ageing over six months, and another study where a 10% Vitamin C formulation did not show significant depigmentation effects. A clinical study evaluating 5% Vitamin C over six months showed improvement in photoaged skin. Systematic reviews also support the use of Vitamin C for uneven and wrinkled skin, with some depigmentation effects noted, although noticeable results require long-term application. Other studies and reviews reinforce Vitamin C's role in inhibiting melanin production, but they differ in concentrations and application timelines, ranging from two to sixteen weeks. While Vitamin C has shown effect in reducing dark spots, the variability in concentration, duration, and formulation across studies makes it difficult to confirm this effect for the advertised serum. Based on this assessment, the CCC concluded that the claims, “It also triggers collagen production giving you glowing youthful skin without invasive treatments [voiceover claim] / Triggers collagen production = tighter, youthful skin / Increases Collagen production & reduces dark spots”, were inadequately substantiated. The claims are misleading by exaggeration and are likely to lead to widespread disappointment in the minds of consumers. The source and date for the claims is not mentioned in the advertisement. The said claims 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 – “...But the results brighter firmer and more radiant skin [voiceover claim] / Brighter, firmer, glassier skin — minus the drama” The CCC reviewed the documents submitted in support of this claim. The CCC discussed that while the serum may contribute to firmer skin due to its role in increasing collagen expression, there is no evidence submitted that adequately supports the effect of the serum in making the skin appear brighter or more radiant. The data provided focuses on the impact of Vitamin C on hyperpigmentation and collagen production. However, the concentration of Vitamin C varies significantly as does the time frame required to observe visible effects, which ranges widely. Moreover, considering the serum contains additional ingredients beyond Vitamin C, a study evaluating its overall effect on skin brightness and radiance was not provided. Based on this assessment, the CCC concluded that the claims, “...But the results brighter firmer and more radiant skin [voiceover claim] / Brighter, firmer, glassier skin — minus the drama”, were inadequately substantiated. The claims are misleading by exaggeration and are likely to lead to widespread disappointment in the minds of consumers. The source and date for the claims is not mentioned in the advertisement. The said claims in the advertisement contravened Chapter I, Clauses 1.1, 1.2, 1.4 and 1.5 of the ASCI Code. This complaint was UPHELD.