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ASA Adjudication on Crawford Healthcare Ltd

Crawford Healthcare Ltd


4 April 2012


Internet (display)


Health and beauty

Number of complaints:


Complaint Ref:



Claims in an internet display ad, viewed on 31 October 2011, promoted an emollient cream range. Text stated "THE ONLY Total Emollient Therapy range without sodium lauryl sulphate (sls)".


Alliance Pharmaceuticals challenged whether the claim "THE ONLY Total Emollient Therapy range without sodium lauryl sulphate (sls)" was misleading and could be substantiated.

CAP Code (Edition 12)


Crawford Healthcare Ltd (Crawford Healthcare) said they considered their five QV emollient variants to comprise a "total emollient therapy", because their products covered the complete needs for a patient with compromised skin hydration. They said that, as pharmaceutical markets grew, mature definitions constantly developed and evolved, stating that the term "complete emollient therapy" was a relatively new term. Crawford Healthcare said they believed their range was broader, with more specific product variants than any other in the UK, and said no product in their range contained sls. They said they therefore believed it was appropriate to state "THE ONLY Total Emollient Therapy range without sodium lauryl sulphate (sls)".



The ASA noted that Crawford Healthcare considered their product range was a "total emollient therapy" range rather than a "complete emollient therapy" range because they believed their range was broader with more product variants. However, we considered that in the context of the ad, most readers would expect the terms to be interchangeable, because both definitions referred to a full range of products that could be used to provide a patient's treatment. Because we understood that Crawford Healthcare was not the only provider who had a full range of emollient therapy products without sls, we considered the claim had not been substantiated, and concluded it was misleading.

The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation), 3.38 (Other comparisons) and 12.1 (Medicines, medical devices, health-related products and beauty products).


The ad must not appear in its current form again. We told Crawford Healthcare not to claim they were the only emollient range without sls.

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