NAD, the advertising industry’s self-regulatory forum, recommended that certain claims for Irwin Natural’s ‘Doctor Developed Clear Pure Complexion’ dietary supplement, including the claim that the product was ‘scientifically developed’, be discontinued.
Skin care claims
The issue surrounded claims that the beauty from within product could improve skin health as well as treat or eliminate acne, although it was not clear that the claims were based on testing of certain ingredients, rather than on the product itself, leading NAD to conclude that the claims must be expressly qualified as ingredient claims.
In its response, Irwin Naturals said it believes “a marketer should be able to make reasonable claims for the formula as a whole based on the fact that the formula contains ingredients that have been shown to be efficacious.”
“Nevertheless, in the spirit of cooperation and support of the self-regulatory process, and despite the above-stated differences with certain findings, Irwin agrees to respond constructively and effectively to the recommendations contained in the NAD decision.”
The advertising watchdog says it recognized that some general claims promising health benefits can be substantiated without clinical studies of the specific product in question; however, the advertiser must still demonstrate that it is scientifically sound to draw conclusions from outside studies and data and apply them to the performance claimed by the advertised product.
“In this case, while the advertiser provided numerous studies and reference articles on Clear Pure Complexion’s ingredients and their properties, there was no actual product testing in the record, and no direct evidence that the product itself would have the same effect as an individual ingredient alone,” NAD said in a statement.
“NAD has consistently held that the nature and extent of claims made by an advertiser should mirror the precision and specificity of the data relied on as substantiation.”