National Advertising Division (NAD)
BBB National Programs National Advertising Division Recommends Discontinuation of Dramatization in TV Commercial for Sensodyne ProNamel Intensive Enamel Repair Toothpaste; Finds Other Claims Supported
Contact: Laura Brett, Vice President, NAD
New York, NY – December 19, 2019 – The National Advertising Division has recommended that GlaxoSmithKline Consumer Health discontinue a dramatization used in two television commercials for Sensodyne ProNamel Intensive Enamel Repair Toothpaste after determining that it reasonably conveyed to consumers the unsupported implied claim that ProNamel toothpaste fills and heals small, deep cracks on surface enamel. Further, NAD concluded that the claim that ProNamel toothpaste provides “next level” or “innovative” sodium fluoride technology was supported. The claims were challenged by The Procter & Gamble Company, manufacturer of Crest toothpaste and other oral health care products.
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.
The claims at included:
- ProNamel toothpaste provides “next level” or “innovative” sodium fluoride technology, beyond the typical remineralization effect marketed for decades.
- ProNamel toothpaste heals cracks “deep within the tooth [or enamel] surface.”
- ProNamel toothpaste “repair[s] what has already been damaged,” including the cracks in teeth shown in the advertisement.
- The product demonstration falsely communicates that ProNamel toothpaste fills and heals cracked enamel.
Tooth enamel is the hard, protective outer layer of the tooth. Exposure to acids from foods or drinks can weaken and destroy tooth enamel. Once enamel is lost it will never grow back or be replaced. Fluoride is a naturally occurring mineral that can be found in most toothpastes. While fluoride helps to repair and strengthen weak spots on existing enamel, it cannot repair or strengthen tooth enamel that no longer exists, including enamel that has been cracked, chipped or otherwise permanently destroyed. At issue, was whether a dramatization shown during the television commercials for ProNamel toothpaste, a fluoride-based toothpaste, conveyed the misleading message that ProNamel fills and heals cracks on the tooth enamel surface.
NAD determined that the dramatization – a close-up illustration of ProNamel’s minerals entering small, deep crevices on the surface enamel, the immediate sealing of those crevices, and the emergence of smooth, unblemished tooth enamel –reasonably conveyed the message that ProNamel can fill and heal small, deep crevices (or cracks) on surface enamel that are caused by acid erosion, leading to visibly repaired enamel. NAD noted that, in the context of the dramatization, claims that the toothpaste is “innovative” and “takes minerals and drives it deep into the tooth surface” to “repair what’s already been damaged,” serve to heighten the message that ProNamel’s unique reparative capabilities extend to sealing small, deep cracks on the surface enamel.
Although the advertiser argued that the dramatization represented an accurate depiction of microscopic “erosive lesions” on acid-weakened enamel, NAD concluded that even if consumers understood that the dramatization was a microscopic image of acid-weakened enamel, consumers viewing the dramatization could still reasonably takeaway the message that ProNamel fills and heals microscopic cracks on the surface of enamel, and that its ability to fill cracks on a microscopic level would ultimately result in a visibly smooth, unblemished enamel surface. Consequently, NAD determined that the advertiser’s proposed disclosure, “Dramatization of Microscopic Damage to Enamel Surface,” does not alter the key message reasonably conveyed by the advertising.
While NAD appreciated the advertiser’s uncontroverted evidence that treatment with ProNamel increases the fluoride in enamel, makes enamel harder, and makes enamel more resistant to dietary acids, NAD determined that such evidence does not support the implied message that ProNamel can fill and heal small, deep cracks on surface enamel. Thus, NAD recommended that the dramatization be discontinued. NAD noted that nothing in this decision prevents the advertiser from truthfully and accurately touting the benefits of fluoride or the formulation of its ProNamel toothpaste.
Finally, based on the uncontested evidence that ProNamel is uniquely formulated to promote optimal fluoride uptake and to avoid inactive ingredients that can impede fluoride’s effectiveness, NAD found there was a reasonable basis to support the advertiser’s “next level” and “innovative” toothpaste claims.
In its advertiser’s statement, GSK stated that it will “comply with NAD’s recommendations and take them into consideration in future advertising.”
About the National Advertising Review Board (NARB): NARB is the appellate body for advertising industry self-regulation. NARB’s membership is composed of 87 professionals from three different categories: national advertisers (49 members), advertising agencies (26 members), and public members (12) made up of academics and former members of the public sector.
About BBB National Programs: BBB National Programs (BBB NP) 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. The programs were formerly administered by the Council of Better Business Bureaus. BBB NP 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.