03.16.22
The National Advertising Division (NAD) of BBB National Programs recommended that Procter & Gamble, the No. 1 company in Happi's Top 50 Report, discontinue the claim that Olay body wash “improves skin 3X better” than the leading body wash. NAD also recommended that the advertiser modify the disclosure in its “Lessons in Layering” print advertisement to accurately identify the body wash used in its supporting study.
These claims, made by P&G in digital, print, and TV advertising, were challenged by Unilever United States, Inc. Unilever is ranked No. 1 in Happi's International Top 30 Report, which profiles the leading players in the global household and personal care marketplace with headquarters outside the US.
In each of the challenged advertisements, NAD found one reasonable interpretation of the “improves skin 3X better” claim to be that P&G’s Olay Premium body wash improves skin three times better with regard to any one of the skin attributes mentioned in the context of the advertisement, such as brightness, smoothness, radiance, hydration, or wrinkles. Even when the 3x improvement claim is not featured alongside other skin attributes, NAD found that the net impression is still one of general skin improvement. In addition, NAD concluded that the claim conveyed a comparative superiority message versus Unilever’s Dove.
Further, NAD determined that the disclosure “versus the leading body wash after 14 days, based on clinical moisture retention” was not sufficient to qualify the takeaway of the claim “improves skin 3X better” to clinical moisture retention.
As support for its claims, P&G relied on the results of its Leg Controlled Application Test (LCAT), a clinical method for in vivo testing of cleansing products. NAD found that P&G’s LCAT methodology is consumer-relevant and tested an appropriate population.
However, NAD concluded that the LCAT study was not a good fit to support the claim that Olay body wash “improves skin 3X better” than Dove body wash because:
• P&G’s calculation of the 3X ratio of improvement of Olay Ultra Moisture over Dove Deep Moisture is not accurate or consumer-relevant; and
• The testing P&G submitted only tests for moisture retention or moisturization, therefore the LCAT results do not support the 3X improvement messages reasonably conveyed by the challenged advertisements.
For these reasons, NAD recommended that P&G discontinue the claim that Olay body wash “improves skin 3X better” than the leading body wash.
In addition, NAD noted that the disclosure in P&G’s “Lessons in Layering” print advertisement references a clinical study on Olay Premium body wash, whereas the clinical study submitted by P&G to support the claims was conducted on Olay Ultra Moisture body wash. While NAD found the difference between Olay Ultra Moisture and Olay Premium body washes to be non-material, it recommended that the disclosure be modified to accurately state the product used by the participants in P&G’s LCAT.
Finally, based on P&G’s assurances that a challenged print advertisement featuring Olay Cleansing and Nourishing Body Wash with B3 and hyaluronic acid and television commercials titled “A Struggle” are not current and have been permanently discontinued, NAD did not review these on the merits.
In its advertiser statement, P&G stated that it “agrees to comply with NAD’s recommendations” and noted that it “remains a strong supporter of the industry self-regulatory process.”
NAD provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the US. It reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.
All BBB National Programs case decision summaries can be found in the case decision library.
These claims, made by P&G in digital, print, and TV advertising, were challenged by Unilever United States, Inc. Unilever is ranked No. 1 in Happi's International Top 30 Report, which profiles the leading players in the global household and personal care marketplace with headquarters outside the US.
In each of the challenged advertisements, NAD found one reasonable interpretation of the “improves skin 3X better” claim to be that P&G’s Olay Premium body wash improves skin three times better with regard to any one of the skin attributes mentioned in the context of the advertisement, such as brightness, smoothness, radiance, hydration, or wrinkles. Even when the 3x improvement claim is not featured alongside other skin attributes, NAD found that the net impression is still one of general skin improvement. In addition, NAD concluded that the claim conveyed a comparative superiority message versus Unilever’s Dove.
Further, NAD determined that the disclosure “versus the leading body wash after 14 days, based on clinical moisture retention” was not sufficient to qualify the takeaway of the claim “improves skin 3X better” to clinical moisture retention.
As support for its claims, P&G relied on the results of its Leg Controlled Application Test (LCAT), a clinical method for in vivo testing of cleansing products. NAD found that P&G’s LCAT methodology is consumer-relevant and tested an appropriate population.
However, NAD concluded that the LCAT study was not a good fit to support the claim that Olay body wash “improves skin 3X better” than Dove body wash because:
• P&G’s calculation of the 3X ratio of improvement of Olay Ultra Moisture over Dove Deep Moisture is not accurate or consumer-relevant; and
• The testing P&G submitted only tests for moisture retention or moisturization, therefore the LCAT results do not support the 3X improvement messages reasonably conveyed by the challenged advertisements.
For these reasons, NAD recommended that P&G discontinue the claim that Olay body wash “improves skin 3X better” than the leading body wash.
In addition, NAD noted that the disclosure in P&G’s “Lessons in Layering” print advertisement references a clinical study on Olay Premium body wash, whereas the clinical study submitted by P&G to support the claims was conducted on Olay Ultra Moisture body wash. While NAD found the difference between Olay Ultra Moisture and Olay Premium body washes to be non-material, it recommended that the disclosure be modified to accurately state the product used by the participants in P&G’s LCAT.
Finally, based on P&G’s assurances that a challenged print advertisement featuring Olay Cleansing and Nourishing Body Wash with B3 and hyaluronic acid and television commercials titled “A Struggle” are not current and have been permanently discontinued, NAD did not review these on the merits.
In its advertiser statement, P&G stated that it “agrees to comply with NAD’s recommendations” and noted that it “remains a strong supporter of the industry self-regulatory process.”
NAD provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the US. It reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.
All BBB National Programs case decision summaries can be found in the case decision library.