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Bulletin: 22/3
Batch: 279
Reference: 39018
Product: Health & Beauty (Beauty)
Advertiser: Foreo Luna
Influencer: Faces by Grace
Agency:
Medium: Social Media (Blogger's Own Page)
Codes:
ASAI Code 7th Edition: 2.4(c), 3.3, 4.1, 4.4, 11.1
A post on an Influencer’s Instagram account featured an image of a hand holding a facial cleansing pad/brush and informed viewers of the following:
“My Skincare Routine. Using the Foreo Luna 3 in my every day routine has taken my skincare to the next level! Whether it’s a deep cleanse or a firming massage, this bad boy has me covered! @foreo_uk Luna 3 is perfect for keeping in the shower and a lovely way to wake up my face in the mornings. It is also the perfect extra step when removing makeup after a long day as it give (sic) the skin a deep cleanse & I love using it when I’m double cleansing! My skin looks and feels great and I feel like I’m giving it that TLC that it needs #ad #LUNA3 #FOREO #glowingskin #skincarejunkie #facialcleanser #acneremoval …”
The complainant considered that the reference to #acneremoval in the advertisement alluded to the fact that the device would cure acne which they considered to be misleading.
Advertiser Response:
On behalf of the advertisers, it was confirmed that the Foreo Luna 3 was a cosmetic device, used for the purpose of facial cleansing which could help improve general facial skin conditions. They said it was not a medical device and could not be used as such to cure any skin health condition.They said that the Foreo Luna 3 was the third generation of the device and it had never been advertised as a device that cured any type of skin health condition. They considered this to be visible from their product packaging and their official website.
The advertisers said that the Influencer’s post had described the product as a cleansing device, used as a step in a skincare routine, even though it had contained the tag #acneremoval, this was included as an internal recommendation.
The advertisers said they recognised that the tag #acneremoval could be interpreted as a claim that the device cured acne, and for that reason, they instructed their team to contact the Influencer to have the tag removed.
In conclusion the advertisers said they would be reviewing all influencer collaborations to see if the same tag was included but they believed that this was an isolated incident as "acne removal" was not a part of the Foreo Luna 3 advertising campaign.
(Note: at the time of drafting the #acneremoval had not been removed from the relevant post)
Influencer Response:
On behalf of the influencer, it was advised that she had not stated anything medical in the advertisement. The hashtag had related to how this product had personally helped her irritable skin and had been based on her own personal experience.On receipt of the draft case report, however, the ASAI was advised that the post in question
had been removed.Complaint upheld.
The Complaints Committee considered the detail of the complaint and the responses received. They also noted the confirmation from the Influencer that the post had been removed.
The Committee noted that the claim #acneremoval had been included in line with a recommendation from the advertisers and that substantiation that the product would result in the removal of acne had not been received.
They considered that the initial inclusion of the #acneremoval was in breach of Code sections 4.1 and 11.1.ACTION REQUIRED:
As the post had been removed no further action was required in this case.