BBB National Programs Archive
NAD Recommends New Nordic Discontinue Challenged Claims, Testimonials for ‘Skin Care Collagen Filler’ Dietary Supplement
New York, NY – Nov. 24, 2015 – The National Advertising Division has recommended that New Nordic U.S.A., Inc., discontinue certain claims for the company’s “Skin Care Collagen Filler” dietary supplement, including claims that the product “reduces the formation of wrinkles.”
NAD is an investigative unit of the advertising industry’s system of self-regulation. It is administered by the Council of Better Business Bureaus.
NAD requested substantiation for claims that included:
- “Reduces formation of wrinkles.”
- “For fine and supple skin.”
- “New Nordic introduces Skin Care™ – a new supplement designed to activate your skin’s cells to generate more anti-wrinkle collagen and help your skin stay healthy and youthful looking. The ingredients will better reach the deepest layers of your skin where no anti-aging cosmetic serum reaches.”
- “Collagen Filler with Proven Ingredients.”
- “Promotes health skin.”
- “Helps reduce the formation of new wrinkles.”
- “Promotes the skin’s own formation of collagen.”
- Diana is 29 years old and works as a sales assistant in Copenhagen. “I have always loved the outdoors and staying in the sun, even without protection. But unfortunately, my skin started showing signs of wrinkles already in my 20s, particularly on my forehead, which frustrated me a lot. So much so that I chose to get bangs. . . Now, I have used the tablets for six months and they really work for me. I am ready to get rid of my bangs and show my forehead again. I don’t feel like stopping the tablets because I feel my skin looks better, tighter, and healthier.”
In response to NAD’s inquiry, the advertiser explained that its product contains dietary nutrients that are designed and proven to support and maintain optimal skin health, including maritime collagen, pomegranate extract, microalgae, tomato extract, vitamin C, zinc, and black pepper.
According to the advertiser, each ingredient possesses specific properties that have been proven by ingredient studies to confer significant and noticeable skin-related benefits.
NAD determined that the challenged claims reasonably convey the message that by taking the dietary supplement Skin Care Collagen Filler, consumers will obtain noticeably younger-looking skin.
In support of the challenged product performance claims, the advertiser cited to 23 ingredient studies – nine were conducted in vitro, seven were conducted on animals and the remaining seven studies were conducted on human subjects. Ingredient studies are, as a general rule, insufficient to support product performance claims. As a general rule, while animal studies and in vitro studies can provide useful background information on an ingredient’s biological effect, they have limited, if any, probative value on the impact of a substance (or a product) which is consumed by humans.
Given that the advertiser submitted no human clinical studies as support for the challenged product performance claims, and that there was no evidence in the record that animal and/or in vitro studies could be considered acceptable substitutes for human clinical trials as they relate to product performance claims for skin care dietary supplements, NAD determined that the animal and in vitro studies were insufficient to support the challenged product performance claims.
As for the remaining ingredient studies on human subjects, only abstracts were available for four out of the seven studies and the abstracts were not sufficiently detailed to afford NAD the opportunity to determine whether the studies constituted competent and reliable scientific evidence.
Two of the three full-length studies assessed collagen extracts or peptides, but it was unclear whether the collagen found in those studies was the same form of collagen found in the product. Further, NAD noted, even if the collagen studied was the same as the collagen found in the product, the amount of the collagen administered in the studies was at least five times the amount found in one dose of the actual product.
Following its review of the evidence in the record, NAD recommended that the claims and testimonial at issue be discontinued.
New Nordic, in its advertiser’s statement, said the company “will take NAD’s recommendations into account in its future advertising and ensure that it complies with any relevant regulatory authority.”
Note: A recommendation by NAD to modify or discontinue a claim is not a finding of wrongdoing and an advertiser’s voluntary discontinuance or modification of claims should not be construed as an admission of impropriety. It is the policy of NAD not to endorse any company, product, or service. Decisions finding that advertising claims have been substantiated should not be construed as endorsements.