Hindustan Unilever Limited - Lux Clear Glow Soap Sandalwood

Recommendation: Upheld | Medium: Industry Member

The FTC panel noted the following submissions made by the complainant: The complainant challenged the following objections against the advertiser’s advertisement for their product – `Lux Advanced Clear Glow soap’. Claim – “Yeh sirf sabun nahin, yeh skin care hai” or “Skincare in a Soap” The claim is misleading consumers by exaggeration into believing that the utility of the impugned product is more than mere cleansing. To equate and claim that the impugned product is elevated from a soap to a typical skin care product is scientifically untenable. The advertiser identifies it as a “bathing bar” but portrays it as a “soap” in the advertisement, which is a blatant misrepresentation. Claim – “Daag Kum Kare” The visuals show instant transition from spots to flawless skin. The same is deceptive and misleading. While the claim made orally is “reduction of spots”, the impugned advertisement itself showcases elimination of spots. The instant transition (as depicted) and elimination of spots by usage of soap is scientifically untenable. Claim – “100% pure sandalwood oil” In the impugned advertisement, it is claimed that the product contains “100% pure sandalwood oil”. “100% pure” is an absolute purity claim that needs to be substantiated by the advertiser. The FTC panel noted the following submissions made by the advertiser: Claim – “Yeh sirf sabun nahin, yeh skin care hai” or “Skincare in a Soap” The findings of the clinical study provide substantiated evidence that the product demonstrated statistically significant improvement in Skin Clarity, Skin Glow and Radiance..., Spot colour lightening, and reduction in Spot pigmentation... The product has been duly registered as a bathing bar and not as a leave on product. The product falls under the category of bathing bars and hence complies with the BIS regulations for bathing bar. The compositional standard primarily based on TFM does not necessarily correlate with the performance of toilet soaps. Claim – “Daag Kum Kare” The visuals illustrating the fading of blemishes are adequately supported by the disclaimer `Basis Clinical study by independent clinical research organization, 2024. With Regular use’. The claim of ‘reduce spots’ is substantiated by a clinical study. The post usage frames clearly show the presence of spots, thereby substantiating the claim of ‘daag kam kare’ (fading of spots) rather than complete elimination. The objectionable frames were duly modified. Claim – “100% pure sandalwood oil” The sandalwood oil used in the product formulation is 100% pure, as substantiated by the supplier’s certification. The FTC Panel’s 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 - “Yeh sirf sabun nahin, yeh skin care hai” or “Skincare in a Soap” The FTC panel observed that the complaint challenged the said claims on two grounds: first, whether the product offers skin care benefits beyond cleansing, and second, whether it can be referred to as a `soap’ given its classification. The FTC panel further observed that the advertiser submitted clinical study involving female participants, who used the product twice daily over a four week period. The study assessed skin glow, radiance, skin clarity, spot lightening, melanin content of pigmented spot. The participants reported visible improvements in all parameters. The skin imaging analysis further showed a reduction in pigmentation and melanin levels over time. Additionally, a skin sensitivity test confirmed that the product did not cause irritation. Based on the clinical findings and test results, it was observed that the product delivers skin care benefits beyond basic cleansing. Regarding the second objection, the issue raised was the use of the term “soap” when the product is classified as a bathing bar, as per Bureau of Indian Standards. The FTC panel observed that the documentation provided by the advertiser supports the classification of the product as a bathing bar based on its Total Fatty Matter (TFM) content. The advertiser also submitted references from Bureau of Indian Standards where the term `soap’ is used in the context of bathing bars. The supporting material including clinical data and technical literature, indicated that even with lower TFM, such bars can offer effective skin care benefits. Based on this assessment, the FTC panel concluded that the claim, “Yeh sirf sabun nahin, yeh skin care hai” or “Skincare in a Soap”, was substantiated and is not in contravention of Chapter I of the ASCI Code. This complaint was NOT UPHELD. Claim 2 – “Daag Kum Kare” The FTC panel observed that the skin care benefits of the product, including reduction in pigmentation, were supported by clinical data submitted by the advertiser. The visual showing a female model’s cheeks depicts complete disappearance of pigmented spots, which may mislead consumers into expecting total removal, although the evidence supports visible reduction rather than complete elimination. The FTC panel further observed that the claim, “Daag Kum Kare,” accompanied by a visual depicting spot removal, is supported by a disclaimer stating, “Basis Clinical study by independent clinical research organization, 2024. With regular use”. However, the communication does not specify the duration of regular use needed to achieve the visible results. The FTC panel was of the view that since the claim relates to skin care performance, the disclaimer needs to state the minimum period required to see the results, to ensure the consumers are informed about the expected time frame. Based on these observations, the FTC panel concluded that the claim, “Daag Kum Kare”, is misleading by omission, and the accompanying visual is also misleading in its presentation. The claim and the visual contravened Chapter I, Clause 1.4 of the ASCI Code. The complaint was UPHELD. The FTC panel noted that the advertiser has subsequently modified the visual in the advertisement. Claim – “100% pure sandalwood oil” The FTC panel evaluated the said claim based on the documentation certifying the quality and origin of the ingredient used in the product. The submitted material included a certification issued by the supplier of the sandalwood oil, confirming that the perfume component used in the formulation is composed of pure sandalwood oil. The certification supports the claim by confirming that the ingredient is 100% pure. Based on the advertiser’s response with the supporting data provided, the FTC panel concluded that the claim, “100% Pure Sandalwood Oil”, was substantiated and is not in contravention of Chapter I of the ASCI Code. This complaint was NOT UPHELD.