Henkel’s challenge sees mixed NAD decision for Revlon’s ColorSilk

Following a competitor challenge brought by Henkel Corporation, the National Advertising Division (NAD) of BBB National Programs (NAD) provided mixed recommendations regarding Revlon’s marketing and advertising behind its ColorSilk hair color with Bond Repair Complex across the brand’s packaging, digital channels and third-party retail platforms.

While several claims were found to be supported, others were flagged for modification or discontinuation, underscoring how narrowly advertising language must track underlying evidence.

Bond repair and anti-breakage claims

According to NAD’s case decision, Revlon substantiated its claim that ColorSilk is made “with a Bond Repair Complex” through tensile strength testing and hair penetration studies tied to key ingredients. NAD “determined that Revlon’s evidence provided a reasonable basis for the claim that Revlon ColorSilk is made ‘with a Bond Repair Complex.”

NAD also reviewed competing anti-breakage studies submitted by Revlon and Henkel in connection with the “up to 98% less breakage” claim. While Henkel argued that differences between the results undermined Revlon’s data, NAD disagreed, finding “Revlon’s study was reliable and that the differences in results were not excessive.”

NAD further noted that variations could reasonably be attributed to differences in testing apparatus, combing protocols and other methodological factors, and ultimately found that Henkel did not demonstrate that Revlon’s testing was fundamentally flawed, allowing the claim to stand.

Inside-out repair claim goes too far

Where NAD drew a firm line was around Revlon’s claim that ColorSilk “repairs hair from the inside out.” In its decision, NAD found that this language conveys a strong message about the extent of hair repair that was not fully supported by the evidence, as the claim “conveys the message that the product produces significant if not complete repair of the hair fiber,” the organization wrote.

While Revlon demonstrated some level of cortex penetration by product ingredients, NAD said the evidence was not robust enough to support the broader implied message, and as a result, recommended that the claim be discontinued.

Testing context shapes smoother and silkier claims

Revlon’s “up to 94% smoother” and “up to 94% silkier” claims were supported by a wet-combing study showing a 94.9% reduction in combing force compared with untreated hair.

NAD found the study itself to be reliable. However, the decision focused on how consumers might interpret the claims when presented without qualification.

“NAD noted that in light of the imagery accompanying the claims, consumers could interpret unqualified claims as applying to dry hair,” the organization wrote, adding that Revlon had not submitted evidence to support dry-hair performance.

Therefore, NAD recommended that the claims be discontinued or modified to clearly communicate that the results are based on wet-hair testing, highlighting the role of context and visuals in determining consumer takeaway.

Voluntary revisions resolve shine and imagery concerns

During the proceeding, Revlon voluntarily revised its “9x shinier” claim to clarify that it is an “up to” claim and to disclose that testing was conducted on the Medium Brown shade, with results varying by shade.

NAD accepted those changes.

“NAD determined that the Revlon study reliably measured shine under consumer-relevant conditions,” the organization wrote, concluding that differences between the parties’ shine results could be attributed to testing variables.

NAD also evaluated implied claims conveyed by before-and-after photographs. Based on Revlon’s assurances regarding image authenticity and its commitment to add shade-related disclosures, NAD found the imagery to be supported.

Revlon further stated that it would update influencer content to include clear and conspicuous material connection disclosures. For compliance purposes, NAD said it will treat the modification as though it had been recommended.

In its advertiser statement included in the case decision, Revlon said it “agrees to comply with NAD’s recommendations.”