National Advertising Division Recommends Simpler Hair Color Discontinue #1 Claims
New York, NY – March 14, 2025 – In a Fast-Track SWIFT challenge brought by competitor Combe Incorporated, BBB National Programs’ National Advertising Division recommended Simpler Hair Color Inc. discontinue claims that its Simpler Hair Color products are rated the “#1” men’s hair color and beard color.
Fast-Track SWIFT is an expedited process by the National Advertising Division (NAD) for reviewing single-issue advertising cases.
Combe manufactures and sells men’s hair and beard color products, including the market-leading Just for Men brand. Simpler markets its brand of “safer and simpler” hair and beard coloring products sold directly through their website, and recently, Amazon. The challenged online advertising stated that Simpler Hair Color products are “Rated #1 Men’s Hair Color*” “*Based on Trustpilot.com verified reviews as of 10/10/2024” and “Rated #1 Men’s Hair & Beard Color*” “*Based on Trustpilot.com verified reviews as of 10/10/2024.”
Combe contended that Simpler’s “#1” claims are false because there is no “Men’s Hair Color” category on Trustpilot.com and that Simpler is not listed as #1 in any Trustpilot category. Simpler responded that the “#1 rated claims” are substantiated based on verified reviews of its product as compared to Combe's Just For Men and other men’s hair color products hosted on Trustpilot.com. Simpler submitted that there are only a few brands primarily dedicated to men’s hair color products offered in natural shades, and that it would not be reasonable to consider “novelty” hair color brands who offer hair color products for men and women in shades such as pink and purple.
NAD found that Simpler’s #1 claims reasonably convey a message that the claim is based on reviews in a recognized category on Trustpilot.com, indicating to consumers that “Men’s Hair Color” is a category when it is not. In addition, NAD determined that the record did not show that the men’s hair color products reviewed on Trustpilot were in any way representative of the men’s hair color products on the market such that the #1 claims would be based on a meaningful comparison of the competing men’s hair color products in the market.
For these reasons, NAD recommended that the challenged claims be discontinued.
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. Pursuant to NAD/NARB Procedures, this release may not be used for promotional purposes.
Fast-Track SWIFT is an expedited process by the National Advertising Division (NAD) for reviewing single-issue advertising cases.
Combe manufactures and sells men’s hair and beard color products, including the market-leading Just for Men brand. Simpler markets its brand of “safer and simpler” hair and beard coloring products sold directly through their website, and recently, Amazon. The challenged online advertising stated that Simpler Hair Color products are “Rated #1 Men’s Hair Color*” “*Based on Trustpilot.com verified reviews as of 10/10/2024” and “Rated #1 Men’s Hair & Beard Color*” “*Based on Trustpilot.com verified reviews as of 10/10/2024.”
Combe contended that Simpler’s “#1” claims are false because there is no “Men’s Hair Color” category on Trustpilot.com and that Simpler is not listed as #1 in any Trustpilot category. Simpler responded that the “#1 rated claims” are substantiated based on verified reviews of its product as compared to Combe's Just For Men and other men’s hair color products hosted on Trustpilot.com. Simpler submitted that there are only a few brands primarily dedicated to men’s hair color products offered in natural shades, and that it would not be reasonable to consider “novelty” hair color brands who offer hair color products for men and women in shades such as pink and purple.
NAD found that Simpler’s #1 claims reasonably convey a message that the claim is based on reviews in a recognized category on Trustpilot.com, indicating to consumers that “Men’s Hair Color” is a category when it is not. In addition, NAD determined that the record did not show that the men’s hair color products reviewed on Trustpilot were in any way representative of the men’s hair color products on the market such that the #1 claims would be based on a meaningful comparison of the competing men’s hair color products in the market.
For these reasons, NAD recommended that the challenged claims be discontinued.
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. Pursuant to NAD/NARB Procedures, this release may not be used for promotional purposes.