Problem Food Claims: breaches the UK ad rules for making unauthorised hair health and growth claims for the “Cocoa Locks” hair growth programme on the website

After reviewing the Cocoa Locks website, this entry has been reissued on 28 March 2024 as, despite some amendments, it continues to make claims that break the rules.

Section 15 of the CAP Code states that only health claims listed as “authorised” on the GB Register of Nutrition and Health claims are permitted in marketing communications. In order to comply, an advertiser needs to show that the health claims for each of their advertised products are listed as authorised on the GB Register and that the authorised claims relate to the relevant ingredient in the product. 

The ASA investigated claims which appeared on for its hair growth programme. Claimed Cocoa Locks results included “Longer, Stronger & Thicker Hair. Guaranteed.”, “Clinically Proven Fast Hair Growth”, “… my hair is longer, stronger and my hair grew 5 inches in the first 2 months” and “Increased collagen production for extra strength, Decrease in hair loss, Increased speed in hair growth, Prevention of hair breakage”. The ASA considered that consumers would understand those claims to mean that Cocoa Locks results would include their hair growing at an increased rate, becoming stronger and that there would be a reduction in hair loss.

Whilst amendments have been made to the Cocoa Locks website, the products are still being advertised as a “Hair Growth Program”. The Chocolate Milkshake product page also states “daily remedy to repair, rebuild, grow and strengthen your hair”. So problematic claims continue to be made.

Cocoa Locks did not respond to the ASA’s enquiries and did not identify any authorised health claims on the Register relating to the product or any of its ingredients. The ASA ruled that the health claims breached the CAP Code and told Cocoa Locks to remove them from its website. The ASA reminded Cocoa Locks to ensure that future ads only made health claims which were listed as authorised on the EU Register (now the GB Register).

Despite requests from the CAP Compliance team to remove the unauthorised health claims, Cocoa Locks continues to feature them on the website.

Because of Cocoa Locks' continued non-compliance, we took the decision, on 28 March 2024, to reissue its company details on this section of the ASA website. These details shall remain in place until such time as Cocoa Locks has removed the unauthorised health claims from to ensure compliance with the CAP Code.

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