Ad description
A product listing for the Exosome Face Lift was seen on the 111SKIN website (111skin.com), on 9 September 2025. Text stated, “Targets Fine Lines & Wrinkles. Clinically proven To Lift The Skin By 20%**”. Small print at the bottom of the page stated, “** Clinical grading assessment using a 10-point scale conducted on 30 participants after 4 weeks of product use”.
Text under the heading “Benefits” stated, “This protocol helps visibly lift and tighten the skin, reduce the appearance of deep wrinkles, and enhance firmness and glow – revealing a smoother, more youthful complexion with every use”.
Text under the heading “Overview” stated, “Visibly renew and rejuvenate the skin in 4 weeks”, “targets advanced signs of ageing by lifting and tightening the skin, addressing fine lines and wrinkles”. Further text stated, “Powered by exosomes which help boost and regenerate the skin barrier, the formulation also leverages an innovative microspicule delivery system which helps enhance the absorption of the active ingredients. A lifting peptide complex supports elastin synthesis to target skin sagging, while a Swiss Ice Wine Extract smooths fine lines. The result is a visibly lifted and tightened effect”.
Issue
The complainant challenged whether the efficacy claims made for the Exosome Face Lift were misleading.
Response
111SKIN Ltd said the ad made cosmetic, appearance-based claims and should be read in the context of an at-home, four-week skincare protocol. It said the product name “Exosome Face Lift 4-Week At-Home Treatment” was used to describe a visible lifting/tightening effect and did not imply equivalence to surgical or in-clinic procedures.
The claim “Clinically proven to lift the skin by 20%” they said was accurate and reflected the outcome of a clinical grading assessment at four weeks. They said the supporting testing showed an improvement in the “lifted aspect” of the skin consistent with the “20%” figure, and that the small print in the ad appropriately explained the basis for the claim.
111SKIN said the ad’s other statements about fine lines and wrinkles, lifting and tightening, firmness, glow and a more youthful-looking complexion were supported by its testing, which they said showed improvements across multiple skin appearance measures over the four-week period. They also said wording such as “reduce the appearance” and “helps visibly” reflected cosmetic effects rather than permanent change.
The description of the “microspicule delivery system” and its role in enhancing absorption they said was supported by penetration and permeability testing. They said that evidence demonstrated increased penetration and permeability with the microspicule delivery system. 111Skin also said the ingredient and mechanism wording, including references to exosomes and peptides, was presented in qualified terms such as “helps” and “supports”, and was intended as explanatory context rather than efficacy or medical claims.
111SKIN provided two consumer perception studies, a human in-use study under dermatological control, and penetration and permeability testing to substantiate their claims.
Assessment
Upheld
The ASA considered that consumers were likely to understand the claim “Clinically proven To Lift The Skin by 20%**” to mean that the Exosome Face Lift produced a noticeable and measurable lifting effect of at least 20%. We considered that impression was supported by the product name, which appeared in the ad as “Exosome Face Lift”, and the claims “helps visibly lift and tighten the skin” and “visibly renew and rejuvenate the skin in 4 weeks”. We considered those claims implied a cumulative lifting effect and we therefore expected to see robust evidence that was the case. We further considered the phrase “clinically proven” was likely to reinforce the expectation of robust clinical evidence to support the headline claim.
The ad also included the product name “Exosome Face Lift” and the accompanying explanatory text, “Powered by exosomes which help boost and regenerate the skin barrier” and “innovative microspicule delivery system which helps enhance the absorption of the active ingredients”. We considered consumers would understand those claims to mean that the product produced a significant lifting effect to the skin on the face, and that the product contained “exosomes” which had an effect on the skin barrier when the product was applied.
We therefore expected to see a high-level body of relevant evidence to support those claims.
111Skin said the claim “Clinically proven To Lift The Skin by 20%**” was supported by a study, with small print in the ad stating, “**Clinical grading assessment using a 10-point scale conducted on 30 participants after 4 weeks of product use”. We assessed whether the study amounted to robust clinical evidence to support that specific efficacy claim.
The clinical study was run for 28-days across 30 subjects. 111SKIN considered all participants were within the target audience for the product. The study used a dermatologist-led clinical grading assessment on a 10-point scale and reported a statistically significant mean improvement of 20.42% in a “lifted aspect” measured at day 28. We acknowledged that there were high levels of agreement for questions relating to the product’s efficacy in the subjective elements of the study. However, the study did not include a placebo or control group and only consisted of 30 subjects. We considered that the “lifted aspect” measure was based on a subjective clinical grading score, rather than an objective measure of lift. We also considered that the objective measures in the tests, which included the subject’s skin roughness, firmness and texture, did not demonstrate a lifting effect to the extent implied by the claim “lift the skin by 20%”.
In addition to the clinical study, 111Skin provided two consumer perception studies. These studies asked participants to respond to questions about the product after two and four weeks of use. We acknowledged that in the results from the studies there was a subjective visible lifting and rejuvenating effect to the skin after 28 days of use. However, the studies did not include placebo or control groups and were self-assessment studies that relied on subjective responses.
111Skin also provided penetration and permeability testing to support their claims. However, that test consisted of one test subject, and the active ingredients were applied to the arm but not to the face. We considered this was insufficient to substantiate the claim of “an innovative microspicule delivery system”. Further, we had not seen any evidence that the exosomes in the product, when applied to the face as part of a serum, had the described effect on the skin. We therefore considered that those claims had not been substantiated. Further, unqualified claims such as “rejuvenation” were not generally acceptable for cosmetic products. We considered that the use of the word “visibly” was insufficient to qualify the claim “renew and rejuvenate the skin” in the context of the ad.
For those reasons, we concluded that the efficacy claims in the ad, including “Exosome Face Lift”, “Clinically proven To Lift The Skin by 20%**”, “helps visibly lift and tighten the skin”, “visibly renew and rejuvenate the skin in 4 weeks”, “Powered by exosomes which help boost and regenerate the skin barrier” and “innovative microspicule delivery system which helps enhance the absorption of the active ingredients”, had not been adequately substantiated, and exaggerated the effects of Exosome Face Lift. We therefore concluded the ad was misleading.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation), 3.11 (Exaggeration), 12.1 and 12.7 (Medicines, medical devices, health-related products and beauty products).
Action
The ad must not appear again in its current form. We told 111SKIN Ltd to not misleadingly exaggerate the effects of cosmetic products on the signs of ageing in facial skin.
