National Advertising Division Recommends Modification or Discontinuance of Comparative Visibility Message in Always Discreet Incontinence Pads Advertising

For Immediate Release

Contact: Laura Brett, Director, NAD, 212.705.0109 / lbrett@bbbnp.org

New York, NY – March 10, 2020 – The National Advertising Division (“NAD”) recommended that The Procter & Gamble Company (“P&G”) modify or discontinue challenged television commercials and print advertising to avoid conveying an unsupported comparative visibility message between its Always Discreet incontinence pads and competing Poise incontinence pads, following a challenge by Kimberly-Clark Corporation (“K-C”).

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

The challenger argued that the 15- and 30-second versions of an Always Discreet television advertisement, as well as print advertising, conveyed the implied message that because Poise pads are thicker than Always Discreet pads, they are visible when worn under form-fitting clothing such as skinny jeans, while Always Discreet pads are not. It was P&G’s position that its commercial does not convey a comparative fit message, rather it conveys a comparative “bulkiness” message – one that is not disputed – and a monadic message about a consumer’s confidence when wearing Always Discreet pads.

Both parties acknowledged that P&G’s Always Discreet pads are thinner than K-C’s Poise pads and that the side-by-side stacking image used in the advertising is an accurate depiction of the products in their packaging. Also, not disputed was the monadic message that a woman wearing Always Discreet pads can feel confident that her pad is not going to be visible or noticeable when worn.  NAD considered whether the advertising also conveys additional implied messages about the competing pads’ relative visibility and determined that both the commercials and the print advertisement reasonably convey the message that P&G’s Always Discreet pads are less visible when worn than K-C’s Poise pads.

NAD noted that there is no evidence that Always Discreet pads, while thinner, are less visible than Poise pads when worn (or that either pad is visible at all when worn under the skinny jeans depicted in the advertising). Therefore, NAD recommended that the challenged advertising be discontinued or modified to avoid conveying an unsupported comparative visibility message.

In its advertiser’s statement, P&G disagreed with NAD’s finding that the challenged advertising communicates comparative visibility, however it agreed to comply with NAD’s recommendations regarding advertising for its Always Discreet product.

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About the National Advertising Division: National Advertising Division (NAD), a division of BBB National Programs, provides independent self-regulation overseeing the truthfulness of advertising across the U.S. NAD reviews national advertising in all media and its decisions set consistent standards for truth and accuracy.

About BBB National Programs: BBB National Programs fosters trust, innovation, and competition in the marketplace through the development and delivery of cost-effective, third-party self-regulation, dispute resolution and other programs. BBB National Programs is the home of industry self-regulatory and dispute resolution programs that include the National Advertising Division (NAD), National Advertising Review Board (NARB), BBB EU Privacy Shield, BBB AUTO LINE, Children’s Advertising Review Unit (CARU), Children’s Food and Beverage Advertising Initiative (CFBAI), Children’s Confection Advertising Initiative (CCAI), Direct Selling Self-Regulatory Council (DSSRC), Digital Advertising Accountability Program (Accountability Program), and the Coalition for Better Advertising Dispute Resolution Program (CBA DRM). The programs are designed to resolve business issues and advance shared objectives by responding to marketplace concerns to create a better customer experience. To learn more about industry self-regulation, please visit: BBBNP.org.