National Advertising Division Recommends Naked & Thriving Discontinue Certain Claims; Advertiser Voluntarily Modifies Bare Beauty Babes Website
New York, NY – March 26, 2024 – BBB National Programs’ National Advertising Division, as part of its routine monitoring program, recommended that Naked & Thriving Inc. discontinue certain claims in the Bare Beauty Babes blog and on social media.
The Bare Beauty Babes blog and an Instagram post contained an article authored by dermatologist Dr. Gabriela Vee - “Does Hyaluronic Acid Help to Fight Signs of Aging? I’ve Tested Hundreds of Hyaluronic Acid Serums – Here are 5 That Actually Work” – with the claim “Peter Thomas Roth Drench Hyaluronic Cloud Serum – This product has a very high amount of hyaluronic acid [75%] in addition to silk proteins, zinc, copper, manganese, iron, and silicon to increase moisture levels and soften skin.”
The Bare Beauty Babes blog is owned and sponsored by Naked & Thriving, a family-owned skincare company. Naked & Thriving works with an agency that runs the Bare Beauty Babes blog.
The National Advertising Division (NAD) recommended that Naked & Thriving discontinue the challenged expert endorsements and that it ensure that expert endorsers have the required expertise and have evaluated the products based on their expertise.
In so finding, NAD noted that:
- There was no evidence in the record related to the qualifications or expertise of the endorser, Dr. Vee;
- The record was silent as to the criteria used to rate or rank the products in the category and whether the endorser reviewed and ranked all products in the category (the posts claim that “dozens” or “hundreds” of products were tested); and
- The advertiser did not provide support that Dr. Vee exercised the expertise of a dermatologist in evaluating the products.
NAD further recommended that Naked & Thriving’s endorsers disclose their connection to the Naked & Thriving brand when that connection is not reasonably communicated by the context of the post.
During the inquiry, Naked & Thriving voluntarily modified the Bare Beauty Babes website to include the connection to Naked & Thriving by adding a disclosure on the top of the website. Also, the website no longer promotes or recommends products, but covers healthy living, beauty, and self-care topics. NAD appreciated the changes and will treat those modifications, for compliance purposes, as though NAD recommended the modifications and the advertiser agreed to comply.
In its advertiser statement, Naked & Thriving stated that it “agrees to comply with NAD’s recommendations” although it “disagrees with certain aspects of NAD’s decision.”
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.
Subscribe to the Ad Law Insights or Privacy Initiatives newsletters for an exclusive monthly analysis and insider perspectives on the latest trends and case decisions in advertising law and data privacy.
Latest Decisions
Direct Selling Self-Regulatory Council Refers Olive Tree Earnings Claims to the FTC and California AG for Possible Enforcement Action
McLean, VA – December 20, 2024 – The Direct Selling Self-Regulatory Council (DSSRC) referred Olive Tree to the Federal Trade Commission (FTC) and California Attorney General's Office for possible enforcement action after Olive Tree failed to respond to a DSSRC inquiry into earnings claims.
Children’s Advertising Review Unit Recommends JustPlay Discontinue or Modify Daisy the Yoga Goat Claims
New York, NY – December 19, 2024 - The Children’s Advertising Review Unit (CARU) launched an investigation into advertising for Just Play’s furReal Daisy the Yoga Goat seeking to determine if the toy’s product packaging and commercial advertisements comply with CARU’s Self-Regulatory Guidelines for Children’s Advertising.
In National Advertising Division Fast-Track SWIFT Challenge, Oral Essentials Voluntarily Modifies “Made in USA” Claims
New York, NY – December 19, 2024 – In a National Advertising Division challenge, Oral Essentials agreed to permanently modify its claim that certain Oral Essentials oral healthcare products are “Made in USA.”
National Advertising Division Recommends Zuru Modify or Discontinue Certain Claims for its Rascals and Millie Moon Diapers
New York, NY – December 18, 2024 – The National Advertising Division recommended Zuru Edge Limited modify or discontinue certain claims for its Rascals and Millie Moon diaper products.