BBB National Programs Archive

NAD Recommends P&G Discontinue Certain Claims for Charmin ‘Ultra’ Products Following Kimberly-Clark Challenge; Can Support Certain Claims

New York, NY – June 7, 2016 – The National Advertising Division has determined that The Procter & Gamble Company can support claims that consumers of its Charmin Ultra Strong and Charmin Ultra Soft products may “Use Up To 4x Less.”

However, NAD found the advertiser’s testing on “double roll” Charmin products was inadequate to support claims made for “mega roll” Charmin products and recommended P&G discontinue certain claims.

NAD is an investigative unit of the advertising industry’s system of self-regulation. It is administered by the Council of Better Business Bureaus.

In this case, the claims at issue were challenged by the Kimberly-Clark Corporation, maker of Scott 1000, a competing bathroom tissue, and included:

  • “USE UP TO 4X LESS.”
  • “With more ‘gos’ per roll…”
  • “Plus it even lasts longer that the leading thousand-sheet brand.”
  • “For us, Mega Roll equals mega value.”

NAD noted that the challenged claims appeared in television and website advertising and on product packaging for Charmin Ultra Strong and Ultra Soft products and fell into three broad categories: Charmin Ultra consumers use “up to 4x less” toilet paper than users of the leading bargain brand, Charmin Ultra Mega Rolls “last longer” than Scott 1000 and provide “more ‘gos’ per roll,” and purchasing Charmin Ultra will save consumers money and is a better value than Scott 1000.

To support its “up to 4x less” claims, the advertiser provided the results of two consumer utility studies, which NAD determined were sufficiently reliable to support the claims. However, NAD that the “up to” portion of the claim appears on the packaging in tiny type, while the words “Use” and “4x less” appear in much larger type. NAD recommended that the advertiser enlarge the words “up to” on product packaging to avoid conveying a misleading “Use 4x less” claim.

NAD next examined the advertiser’s claims that Charmin Ultra Mega Rolls “Last Longer” and provide “More Go’s Per Roll.”  The claims appear in various television advertisements that feature the Charmin bears.

NAD was concerned that the advertiser relied on testing for its Double Roll product for the claims, even though the claims in this category were for its Mega Roll product. The visuals in the advertisements feature and compare the Mega Roll product alongside the Scott 1000 brand, with the voiceover and surrounding images repeatedly calling out the Mega Roll product. NAD determined that in this context a consumer would reasonably expect the advertiser’s testing to have been conducted on the advertised Mega Roll product.

As additional support for these claims, the advertiser relied on its predictive model, which NAD determined did not provide adequate substantiation for these claims. NAD recommended that the advertiser discontinue the claims that Charmin Ultra Mega Rolls “Last Longer” and provide “More ‘Gos’ Per Roll.”

Further, NAD determined that the evidence in the record was insufficient to support the message that a Mega Roll of Charmin will in fact outlast a roll of Scott 1000 to the extent that it will actually save consumers money. NAD recommended that the advertiser discontinue its express and implied value claims.

P&G, in its advertiser’s statement, said the company “agrees to comply with NAD’s recommendations.”

Further, the company said, “P&G continues to have great respect for the industry self-regulatory process and thanks NAD for its commitment to providing its services to the marketing community.”

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.