National Advertising Division Finds Certain Native Brand Personal Care Products Claims Supported; Recommends P&G Modify or Discontinue Others

New York, NY – June 27, 2024 – In a challenge brought by SC Johnson & Son Inc. (SCJ), BBB National Programs’ National Advertising Division determined that certain claims made by Procter & Gamble Company (P&G) for its Native brand of personal care products are supported, including:

• P&Gs use of “simple” in its tagline “Clean. Simple. Effective.” 
• Monadic “safe” claims such as “safe & simple products made without harsh ingredients.”

However, the National Advertising Division (NAD) recommended that P&G:

• Modify or discontinue use of “simple ingredients” when describing Native product ingredients for its deodorants, body washes, body lotion, conditioners, and shampoos.
• Discontinue its “Born in the USA” claim.

SCJ, maker of the Method brand of products, challenged claims found on product packaging, advertising, and Amazon listings for P&G’s Native brand of personal care products.

“Simple” Claims

The National Advertising Division (NAD) determined that one message reasonably conveyed by “simple” in Native’s tagline, “Clean. Simple. Effective,” is that Native products contain few or minimal ingredients. NAD found that P&G substantiated the claim and determined use of the tagline is substantiated in the context of Native’s product packaging and website.

SCJ also challenged Native’s use of “simple” in reference to individual ingredients in Native Products instead of the product formulations as a whole: “simple ingredients,” “simple & effective ingredients,” or “simple ingredients you can understand at a glance.” NAD determined the description of Native ingredients as “simple” is not supported for its deodorants, body washes, body lotion, conditioners, and shampoos and recommended that P&G discontinue or modify its use of the “simple ingredients” claims when describing these products.

Safe Claims

The National Advertising Division (NAD) determined that one message reasonably conveyed by a monadic unqualified “safe” claim is that the product is safe when used as directed. NAD noted that while advertisers are responsible for all messages reasonably conveyed by their advertising, they are not obligated to support unreasonable interpretations of their claims, such as the message that the product is safe for all possible uses, even unintended ones, or that the product is safe for consumers to misuse contrary to product directions. 

NAD found P&G’s monadic “safe” claims, such as “safe & simple products made without harsh ingredients” and “safe, synthetic, sustainable fragrances (free of phthalates),” used on Native products to be supported. 

“Born in the USA” Claim 

The National Advertising Division (NAD) determined that one message reasonably conveyed by P&G’s “Born in the USA” claim is that Native products are made in the USA. NAD noted that the Federal Trade Commission standard for “Made in USA” claims require that “all or virtually all” of the cost of the goods sold be attributable to domestic sources. Since P&G did not provide any evidence that its products are made in the USA, NAD recommended that the claim be discontinued.

During the proceeding, P&G permanently discontinued certain claims. Therefore, NAD did not review these claims on their merits and will treat the claims, for compliance purposes, as though NAD recommended they be discontinued.

In its advertiser statement, though P&G “respectfully disagrees” with certain of NAD’s determinations, it agreed to comply with NAD’s recommendations.

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.