NAD Recommends Guthy-Renker Discontinue Certain Performance Claims for Crepe Erase, Finds Certain Claims Supported; Advertiser to Appeal

New York, NY – Aug. 1, 2019 – The National Advertising Division has recommended that Guthy-Renker discontinue or modify certain express and implied performance claims in video and internet advertising for its Crepe Erase Anti-Aging Body Care Treatment System. The advertiser has said it will appeal part of NAD’s findings to the National Advertising Review Board. Guthy-Renker’s Crepe Erase Anti-Aging Body Care Treatment System consists of two products intended to be used sequentially: (1) Exfoliating Body Polish; and (2) Intensive Body Repair Treatment.

NAD is an investigative unit of the advertising industry’s system of self-regulation and is a division of the BBB NP’s self-regulatory and dispute resolution programs.

As part of its routine monitoring program, NAD requested substantiation for the following claims:

Express Claims:

• “[i]ntense hydration clinically shown to keep your skin moisturized all day in just one application.”
• “prevent accelerated aging for visibly plumper, firmer, younger looking skin.”
• “Crepe Erase is the leading anti-aging body care system clinically shown to reverse crepey-looking skin. Results are instantly visible, and they improve with continued use.”
• “Improvement is immediately visible!”
• “After 1 Use** – 82% of users reported that skin was instantly smoother.” ** Based on a 50-person consumer use survey. Individual results will vary.
• After 4 Weeks† – 90% of users showed improvement in skin firmness on arms.” † Based on a 49-person evaluation by an expert clinical grader. Individual results will vary.
• After 8 weeks‡ – 95% of users experienced a lifted appearance of skin.” ‡ Based on average results of a 50-person evaluation by an expert clinical grader measuring décolleté, arms and knees & legs. Individual results will vary.
• “Crepe Erase is enriched with TruFirm Complex to treat and improve the visible signs of aging while helping to promote healthy collagen and elastin. Contains 3 powerful phytonutrients – apple, dill and sage, clinically shown to combat weakened, crepey skin, revealing a smoother, tighter, more youthful-looking texture.”
• “#1 Anti-aging system for crepey skin that can transform your dry, crepey winter skin into softer, smoother, younger-looking skin all year around.”
• “The #1 Solution for reversing dry, aging, crepey skin on the body.”

Before and after photographs

Doctor Recommended Claim: 

• “The real secret to Crepe Erase is TruFirm that targets the dermal enzymes that break down collagen & elastin. TruFirm promotes your skin’s natural elasticity giving it that youthful looking snap back. Crepe Erase is the only system out there that I recommend to my patients to reverse those signs of skin aging.”

Celebrity Endorsement: 

• “I started using Crepe Erase and saw improvement immediately. I’ve been using it for two years now and I really don’t see any crepey skin.” — Dorothy Hamill

NAD noted that the advertiser makes strong performance claims, coupled with before and after photographs, which promise consumers noticeable and dramatic improvements in crepey skin.  NAD considered whether the evidence in the record supports the challenged claims when the products are used in accordance with their use instructions.

NAD recommended that the claim “Crepe Erase is the leading anti-aging body care system clinically shown to reverse crepey-looking skin” be discontinued.  As for the claim “prevent accelerated aging for visibly plumper, firmer, younger looking skin,” NAD recommended that the “prevent accelerated aging” portion of the claim be discontinued.  Although NAD determined that the study submitted by the advertiser in support of these claims was methodologically sound, it concluded that the study was not a good fit for the challenged claims because the results fall short of complete or near elimination in skin crepiness. NAD determined that the challenged performance claims communicate a substantial reduction in, if not total elimination of, crepey skin (“Crepe Erase is the leading anti-aging body care system clinically shown to reverse crepey-looking skin”; “prevent accelerated aging for visibly plumper, firmer, younger looking skin”) with results that are visible but which improve with continued use.  However, NAD determined that the same study was a good fit, and thus provided a reasonable basis, for the claim that for skin crepiness “Improvement is immediately visible!” and the claim “After 1 Use ** – 82% of users reported that skin was instantly smoother – ** Based on a 50 person consumer use survey.” 

Further, NAD concluded that the claim “[i]intense hydration clinically shown to keep your skin moisturized all day in just one application” was supported, as well as the claims “Results . . . improve with continued use,” “After 4 Weeks† — 90% of users showed improvement in skin firmness on arms,” and “After 8 Weeks‡ — 95% of users experienced a lifted appearance of skin.” However, NAD recommended that the quantified claims be modified to reflect the percentage of subjects showing improvements from the cutometer readings to avoid overstating how many consumers experience these stated results.

With regard to the claim that the Crepe Erase System has the ability to “transform your dry, crepey winter skin into softer, smoother, younger-looking skin all year round,” NAD was concerned because most of the studies in the record were not conducted during the winter.  Given that the clinical study conducted during the winter did not – in NAD’s view – include a valid endpoint which reflects the claims at issue, NAD determined that the study was not sufficiently reliable to determine the impact the products have on winter skin, and recommended that the claim be modified to remove the reference to “winter.”

NAD concluded that the ingredient studies conducted by the ingredient supplier were not a good fit for the claims that Crepe Erase “contains 3 powerful phytonutrients – apple, dill and sage, clinically shown to combat weakened, crepey skin, revealing a smoother, tighter, more youthful-looking texture” and recommended that the claim be modified to avoid linking the benefit to these ingredients.

NAD noted that Guthy-Renker’s advertisements juxtapose the challenged claims promising a reversal of crepey skin with some before and after photographs that in NAD’s view depict dramatic improvements in crepey skin.  Since NAD concluded that none of the studies in the record demonstrate that the look of crepey skin is substantially improved, NAD was concerned that the photos depicted outlier results and were not reflective of the improvements consumers can reasonably expect to achieve when using the products as directed.  Consequently, NAD recommended that the before and after photographs be modified to reflect the results consumers can reasonably expect to achieve when using the product as directed.

With regard to the advertiser’s claims that its Crepe Erase System is the “#1 Anti-aging system” and “#1 Solution” for crepey skin, NAD determined that a “#1” sales claim was supported. However, in an effort to ensure that the claim does not convey a misleading message that Crepe Erase is the best treatment to improve the look of crepey skin, NAD recommended that the claim be modified to refer to “#1 selling” as part of the main claim.

NAD further recommended that the challenged doctor testimonial in which a plastic surgeon says that Crepe Erase is the only system he recommends to his own patients “to reverse those signs of skin aging,” be discontinued or modified to make clear that the doctor’s recommendation is based solely on his assessment of Crepe Erase’s efficacy based on his evaluation of his patients’ experiences with the product as confirmed in his affidavit (not based on a review of competing antiaging products).

Finally, NAD determined that the evidence in the record does not support the claims made in the celebrity testimonial that regular use of the Crepe Erase system will result in complete elimination of crepey skin.  Therefore, NAD recommended that the advertiser discontinue the celebrity testimonial, but noted that nothing in the decision precludes the advertiser from using a testimonial which reflects the results of the studies which demonstrated improvements in the look of crepey skin with continued use.

In its advertiser’s statement, Guthy-Renker stated that it will appeal part of NAD’s decision because it disagrees with NAD’s rulings that: “the claim that ‘Crepe Erase is the leading antiaging body care system clinically shown to reverse crepey-looking skin’ should be discontinued; the claims ‘After 4 weeks – 90% of users showed improvement in skin firmness on arms’ and ‘After 8 weeks – 95% of users experienced a lifted appearance of skin’ should be modified to reflect the results of cutometer readings, when these were the results of expert assessments; the reference to ‘winter’ should be removed from the claim ‘transform your dry, crepey winter skin into softer, smoother, younger-looking skin all year around’; the claims regarding the ingredients should be modified to avoid linking the benefit to the ingredients; the before and after photographs should be modified; and Dr. Ordon’s and Dorothy Hamill’s testimonials should be modified or discontinued.”

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