Ad
A TV ad, for No7 Extreme Length mascara, featured the actress Keeley Hawes; she appeared to be in a dressing room and was holding a mascara wand. On-screen text stated “Styled using lash inserts”. She said “New No7 Extreme Length mascara. So it will make my lashes look a little bit longer then?”. A male voiceover said “No”, to which she responded “A smidgen longer?”; again the male voice said “No”; she then asked “A touch longer?”. She was wearing make-up and a close-up was shown of her lashes while she applied mascara; on-screen text stated “Enhanced in post production”. The voice-over continued “No, it’s called Extreme Length for a reason. Actually, it’s very interesting, the brush and mascara have been specially designed to…”. She was shown with her eyes closing and the voiceover stated “… Keeley?”; she said “Sorry, dropped off. Weight of these extreme length lashes probably”. A female voiceover then stated “New No7 Extreme Length mascara. No7, not just a pretty face”. Text on-screen stated “up to 60% longer looking lashes No7”.
Issue
Eight viewers challenged whether the ad exaggerated the efficacy of the product.
BCAP TV Code
5.1 (old)
Response
Boots UK Ltd (Boots) said the on-screen text was designed to ensure viewers understood the nature of the images and to ensure compliance with the relevant guidance. They said the models look was created by a make-up artist and the lash inserts used in the ad were applied to the upper lids only; they were used to fill gaps in her lashes to create a “natural, visible lash line” that would be clearly visible on-camera and on-screen; seen in conjunction with the text “Styled using lash inserts” viewers would not be misled. They also said the type of lash inserts used were readily available on the high street, or in professional salons, and that by subsequent use of No7 Extreme Length Mascara the desired effect seen in the ad could be achieved; the finished look of the models lashes could easily be achieved using the product and therefore the ad did not exaggerate the finished look consumers would experience. They said the end result was achieved by a combination of the products formulation and the innovative way the mascara sat on the wand, which distributed the product evenly while having a curling effect.
Boots said the statement “Enhanced in post production” referred to the action of the mascara wand sweeping through the models eyelashes; this was done to overcome the difficulty of taking a smooth shot of the mascara being applied using a wand loaded with the product. They said the length, volume and colour of the lashes were altered in post production to replicate the lengthening, volumising and darkening effects of using the mascara; after the shot of the product being applied was shown the enhanced lashes continued to appear to ensure consistency throughout the remainder of the ad.
Boots said they carried out studies, which used scientific measurement and consumer perception studies. The measurements of 40 volunteers individual eyelashes were taken before and after using the product; having divided the entire eyelash into sectors and selected the five longest lashes, the average of the five lash lengths and percentage overall change was calculated. The average change varied from 0% to over 70%, with 11.76% of participants showing a change of over 60% and 23.5% in total showing lengthening of 50% or more. They provided before and after photos as well as information about the wand.
Clearcast said the on-screen disclaimers meant it did not matter how exaggerated the lashes were; because viewers, whose lashes would vary in length, thickness and amount, would realise their lashes would not look the same as those featured. They explained that Boots had submitted evidence, which consisted of consumer perception tests as well as more robust and measurable digital analysis of photographs taken of lashes before and after the application of the product and a diagram of the mascara wand. The evidence, which had been independently verified by a consultant, showed that 53% of participants experienced an increase of up to 30%, a total of 74% showed an improvement of up to 40% and over 11% reported an increase of 60% or more. They pointed out that Boots had used the claim “up to”, which Clearcast considered acceptable in instances where 10% or more participants had experienced the result claimed. Clearcast said they therefore accepted the claim “up to 60% longer…”, provided it was qualified to clarify that the claim referred to the appearance of the lashes only.
Assessment
Not upheld
The ASA noted that the ad made clear that lash inserts were used and the lashes had been enhanced in post production. We noted Clearcasts consultant said the data submitted to him was produced by an acceptable method. We considered that the evidence demonstrated that more than 10% of participants lashes had shown an increase of 60% or more, as required by Clearcast, and the words “up to” were therefore used accordingly. Because we had seen that evidence and the words “longer looking” were included, we considered that viewers were unlikely to be misled into thinking they were guaranteed to notice an increase of 60% in the length of their lashes. We concluded the ad did not exaggerate the efficacy of the product.
We investigated the ad under CAP (Broadcast) TV Advertising Standards Code rule 5.1 (Misleading advertising) but did not find it in breach.
Action
No further action necessary.
Adjudication of the ASA Council (Broadcast)
(Source: Advertising Standards Authority)