Hair care has often played second fiddle to skin care in the cosmetic marketplace, as innovation has been restricted to anti-dandruff and hair conditioning; but with inspiration and innovation taking it from the salon into the household, it raises the question of claim substantiation, according to David Rosslee, Business Development Manager, Reading Clinical Research.
In the UK, the Committees of Advertising Practice (CAP), who writes and maintains the UK Advertising Codes, says that marketers of hair care products should generally restrict their claims to those of a cosmetic nature.
It states that claims that those products can ‘protect’ against damage are likely to be acceptable if evidence is held; but that it has not yet seen evidence which demonstrates that a shampoo or a conditioner can ‘repair’ damage and so robust scientific evidence needs to be held to support claims of this nature, for example.
“The essence of claim substantiation is that a product does what it says on the tin,” adds Rosslee, presenting at the SCS Formulate event in Coventry.
“When looking in the UK, at the Advertising Standards Authority, which deals with advertising and claims complaints, more often than not when concerning hair care, complaints which are upheld are usually made from direct competitors. This shows just how competitive the market is.”
This is an example of how if a brand cannot substantiate its claims, then those in the industry, such as experts or rivals, will challenge the claims formally with the authorities.
The Advertising Standards Authority, is on example of one such body which regularly receives complaints from experts and rivals who challenge claims made in beauty advertising. In many cases when the ASA believes the claims cannot be substantiated, these challenges are upheld.
Last month, Procter and Gamble were told by the UK watchdog to discontinue adverts in the UK for its Nicen’ Easy hair dye, after a senior hair colour educator and a hair colour educator challenged whether the ads ‘misleadingly exaggerated the capability of the product.’
The confusion came because the hair colouring was actually filmed in reverse for secrecy reasons, though P&G maintained the represented effect was still the same.
The ASA said it understood the practical reasons; but as ‘the visual claim had not been substantiated’, and given that the sequence in which the model’s hair was coloured leading up to the TV shoots did not match the depiction in the ad, it was misleading and should not be shown again in the current form.