National Advertising Division Recommends Goose Creek Modify or Discontinue Certain Advertising Claims

New York, NY – October 31, 2023 – In a challenge brought by Bath & Body Works, LLC (B&BW), the National Advertising Division (NAD) of BBB National Programs determined that the tagline “Bath, Body & Home” was not misleading, but recommended that Goose Creek Candles, LLC:

• Discontinue certain claims regarding the ingredients found in competitor’s products.
• Discontinue the challenged claims that Goose Creek candles have longer-lasting and stronger fragrances than its competitors.
• Modify its “Made in USA” claims.
• Modify disclosures used in connection with advertising featuring actors portraying consumers.
• Require the @TheCandleChannel vlogger to disclose material connections in certain videos.
• Modify consumer posts to disclose incentivized reviews.

Ingredient Claims

NAD found that one message reasonably conveyed by Goose Creek’s “avoid the harmful chemicals found in other body care products” claim is that other competitive body care products contain harmful chemicals. NAD determined that the record did not support this claim and recommended that it be discontinued, as well as implied claims that competitors’ products contain harmful chemicals.

Fragrance Claims

NAD determined that the advertising at issue conveys the message that Goose Creek candles last longer and have a stronger fragrance than competitors. NAD found insufficient evidence to support these superiority claims and recommended the following fragrance claims by Goose Creek be discontinued:

• “When it comes to fragrance, Goose Creek beats the competition time and time again” 
• “So much stronger than other store brands”
• “Stronger, longer-lasting fragrances!”

NAD also recommended that Goose Creek discontinue any advertising that implies that Goose Creek candles are stronger or longer lasting than competing candles.    

Made in U.S.A. Claims

NAD recommended that Goose Creek modify its “Made in USA” claims (“poured in the USA with the highest ingredients from around the world”) to be consistent with FTC guidance and limit claims to the processes or candle ingredients that are made in the USA. 

Endorsements

NAD determined that several videos across Goose Creek’s online platforms convey the message that people featured are actually consumers, not actors, who are giving their opinions. NAD recommended that any Goose Creek content featuring actors portraying consumers be modified to clearly and conspicuously disclose, in both audio and video, that actors have been employed in the videos.

Further, NAD reviewed videos posted by a candle vlogger @TheCandleChannel, who became a label designer for Goose Creek Candles in July 2023. NAD determined that Goose Creek’s relationship with @TheCandleChannel vlogger is a connection that would likely affect the weight or credibility of the endorsements and is a material connection that must be clearly and conspicuously disclosed. 

For this reason, NAD recommended that Goose Creek require @TheCandleChannel to modify any video created after the date of employment with Goose Creek to include a clear and conspicuous material connection disclosure. 

Consumer Reviews 

B&BW challenged consumer reviews that appear on Goose Creek’s website as well as 5-star video reviews. NAD found there was no evidence that Goose Creek’s review collection process persuades consumers to leave only positive reviews and determined that Goose Creek’s review collection process incentivizes both positive and negative reviews.

However, because Goose Creek’s incentivized consumer reviews are not disclosed, NAD recommended that all consumer reviews posted or re-posted by Goose Creek be modified to include a clear and conspicuous disclosure that the review was incentivized.

Tagline

NAD determined that the tagline “Bath, Body & Home” does not convey a misleading message that equates Goose Creek products with B&BW products.  

In its advertiser statement, Goose Creek stated that “while Goose Creek believes that its advertising verbiage and methods have truthfully conveyed the many benefits of its products, it appreciates the NAD’s thorough review and guidance” and “agrees to comply with the NAD’s recommendations regarding its advertising.”  

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB procedures, this release shall not be used for advertising or promotional purposes.