Hair loss remains a sensitive area within health and beauty advertising. Balancing persuasive copy with compliant and sympathetic messaging is key to pulling off an ad that complies with the Codes.
Not all hair loss is the same
The ASA and CAP recognise three main types of hair loss, so before publishing ads, it’s important to be clear what you’re talking about:
- Alopecia areata: Patchy, often unpredictable hair loss that can affect the scalp, eyebrows or entire body.
- Chronic telogen effluvium (hair shedding): A temporary imbalance in the hair growth cycle. Importantly, neither the ASA nor CAP have seen evidence that products can treat this condition.
- Androgenetic alopecia (pattern baldness): The most common form, involving gradual thinning in specific patterns.
This distinction matters because ads mustn’t imply that a product works across all forms of hair loss. Overgeneralisation is a common pitfall, so be clear what you’re referring to.
Medicinal vs non-medicinal claims
A central consideration is whether your claim is “medicinal.”
Claims that a product can prevent, cure, or reverse hair loss or baldness are likely to be seen as medicinal because they relate to a physiological function. Advertisers holding the appropriate marketing authorisation from the Medicines and Healthcare products Regulatory Agency (MHRA) are permitted to make efficacy claims in their ads in line with the conditions of this authorisation.
By contrast, claims such as “reduces hair loss”, “strengthens hair” or “stimulates growth” are likely to be non-medicinal, and can usually be made without a marketing authorisation from the MHRA, provided the advertiser holds robust evidence (see: Healthcare: Medicines).
Medicines and prescription-only treatments
Prescription-only medicines (POMs) must not be advertised to the public. (see: 12 Medicines, medical devices, health-related products and beauty products and Healthcare: Prescription-only medicines) So, if you offer Finasteride and Minoxidi in their prescription-only form, you need to be doubly aware of the rules around POMs:
- On websites, make sure named POMs are kept off your homepage and information about them on the rest of your website is balanced, factual and non-promotional (Healthcare: Prescription-only Medicines (websites))
- Compounded, unlicensed medicines must also not be advertised, and ads must not give consumers the impression they can choose or access prescription treatments directly (see: Hims & Hers UK Ltd)
- Clinics or treatment centres offering POMs are permitted to advertise consultations for treatments (e.g. “hair loss consultation”), but not the treatment itself (e.g. “consultation for Finasteride”).
Evidence standards: “robust” means robust
As with ads for all products, objective claims must be backed by evidence. You might think we’re splitting hairs, but don’t be surprised if we insist on advertisers providing solid evidence for claims. Advertisers typically come a cropper with:
- Reliance on study abstracts or summaries rather than full clinical studies
- Studies that aren’t directly related to the product formulation
- Small, unrepresentative sample sizes
- Lack of control groups or objective measurement
- Overreliance on subjective consumer surveys
Even where multiple studies are submitted, the ASA will assess the overall quality and relevance, not just volume. Weak methodology can invalidate otherwise promising data. (see: Guidance on the level of substantiation expected in health, beauty and slimming claims).
Cosmetic vs therapeutic claims
Many hair-related products - such as wigs, fibres or extensions - provide a temporary, cosmetic visual effect. Claims that these products can provide more than just a temporary solution for example to “solve [the]... thinning hair problem” are likely to raise an eyebrow from the ASA.
Creative elements
Advertising always relies on creative elements. But they still need to stick to the rules and advertisers have sometimes got into hot water when creativity hasn’t been grounded in the Code rules. So:
- Before and after images must reflect genuine, typical outcomes and must not exaggerate results.
- Testimonials do not replace clinical evidence – all efficacy claims must be substantiated (Claims in testimonials and endorsements)
- Celebrities must not be used to promote prescription-only or over the counter medicines, including treatments like Minoxidil (see CAP 12.18: 12 Medicines, medical devices, health-related products and beauty products and Health: Celebrities and health professionals).
Supplements and health claims
As with all supplements, a health claim should only be made if the claim is "authorised" and listed on the Great Britain nutrition and health claims (NHC) register.
- Claims must comply with authorised health claims registers (Kollo Health Ltd).
- Advertisers must meet the specific conditions of use.
- General claims about improving hair growth or thickness are often not permitted unless explicitly supported.
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