Background
Summary of Council decision:
Four issues were investigated, three of which were Upheld. The other issue was informally resolved after the advertiser agreed to amend their advertising.
Ad description
A website for ShroomIQ, a children’s supplement brand, www.shroom-iq.com/, seen on 26 October 2025 and a paid-for Facebook ad seen on 14 December 2025:
a. The website homepage stated, “Everything They Need to Thrive - in One Delicious Gummy […] Daily Focus Support Backed by Zinc, which supports normal cognitive function.”
It featured a section stating “Success Stories Parents are noticing positive changes! Their kids seem more focused, settled, and ready to take on the day.* See what they’re saying about ShroomIQ” with a qualification that stated “*Based on individual experiences. Results may vary. For full list of authorised health claims, see our Health Claims page.” One customer testimonial stated, “A Noticeable Difference in Focus & Patience” and “I’ve seen a real change in my son. He has very bad ADHD […] He’s always been easily distracted, jumping from one thing to another, and homework was a nightmare. Lately, he’s been sitting down longer, finishing tasks without frustration, and even his teacher mentioned that he seems more engaged in class.” Another customer testimonial stated “helping my daughter with anxiety” and “My daughter has always been a little anxious […] I started giving her these gummies a month ago, and […] I can tell she’s handling things a bit better. She seems more confident speaking up in class and doesn’t get as frustrated when working through tricky subjects.”
It further featured a section headed “Meet the Experts Behind ShoomIQ” and stated “We teamed up with experts in child nutrition and development to create a gummy carefully formulated with well-studied ingredients. Each one is chosen based on research into areas like focus, learning, and cognitive support.” The page presented five individual profiles, each with a portrait of the individual holding a jar labelled “SuperShrooms for Kids”, their name, professional title, role description and a quote. This included “Dr. Omari Oji – ADHD & Cognitive Development Specialist. Role: Advised on how the formula could support neurodivergent children, especially in focus, mood regulation, and attention span. Quote: ‘I’ve seen firsthand how natural nootropics can support attention and learning. ShroomIQ Kids is a game-changer for parents looking for holistic solutions.’” It further included, “Dr Anhony Thorn – Clinical Director & Pediatric [sic] Specialist”, “Dr Rakesh Patel – Biochemist & Our Formulator”, “Dr Remmie Bilba – Pediatric [sic] Nutritionist & Dietitian” and “Mark Watford – Quality Control & Manufacturing Expert”.
At the bottom of the home page it stated “Some images, including product visuals, names and people shown, are AI-generated representations used for illustrative and branding purposes only.”
The National Library of Medicine Studies page referenced studies carried out on Lion’s Mane, Reishi Mushroom, Saffron, Omega-3 DHA, L-Theanine, Magnesium, Vitamin B6, Vitamin B12, Vitamin C, Vitamin D and Zinc. Included were studies relating to their health benefits and their effects on ADHD, Tourette Syndrome, Anxiety and Depression. The studies further related to their effects on neurological function, mood, attention, emotional balance, behaviour and memory. For each study mentioned, it stated “These studies are not specific to our product. We do not claim the same results.”
b. A paid-for Facebook ad stated “This isn’t a quick fix. It’s brain support for your child built from nature. Packed with 12 natural nutrients including Lion’s Mane, Saffron and Omega-3 DHA to support calm, mood and confidence [brain emoji].” It included an image which stated “One Gummy. 12 Supplements. Zero Fuss.” It listed 12 substances alongside pictures of tablets, with an arrow pointing to one orange gummy accompanied by the text “For Ages 6-16”. Text underneath stated “Nature’s Brain Support for Young Minds”.
Issue
The ASA received one complaint about ad (a) and one complaint about ad (b), from a specialist in neurodivergence. The complainants challenged whether the following claims complied with the Code:
- claims to help with ADHD, Tourette Syndrome, anxiety and depression in ad (a);
- specific health claims in ads (a) and (b); and
- health professional endorsements or recommendations in ad (a).
Response
1. Whilst Birling Shore Ltd t/a ShroomIQ stated that the customer reviews referencing ADHD (attention deficit hyperactivity disorder) and anxiety were genuine, they acknowledged that references to specific medical conditions were considered as marketing claims. They therefore confirmed they had removed all references to such medical conditions and specific testimonials from their advertising and had uploaded new customer testimonials to their website.
2. ShroomIQ stated they understood the need to have regard for the GB Register of Health Claims and said they had trained their marketing team on the authorised claims. They said they would apply stricter disclaimers in future ads so that any wellbeing statements were linked to specific authorised ingredients.
3. ShroomIQ acknowledged the Code’s restrictions on health professionals endorsing supplements and confirmed they had removed the endorsements and quotes from Dr. Omari Oji and other medical professionals from their marketing materials.
Assessment
1. Upheld
The CAP Code (which reflected legislation) stated that claims which stated or implied a food prevented, treated or cured human disease were not acceptable in marketing communications for foods or food supplement products. It also stated that medicinal claims may be made for a medicinal product that was licensed by the MHRA (Medicines and Healthcare products Regulatory Agency) or under the auspices of the EMA (European Medicines Agency). Medicines must have a licence from the MHRA or under the auspices of the EMA before they were marketed.
The ASA noted the website homepage in ad (a) included customer testimonials which referred to “ADHD” and “anxiety”, and described symptoms, in relation to the references to ADHD, such as “Focus & Patience”, being “easily distracted” and “jumping from one thing to another”. In relation to anxiety, the customer testimonial described a child getting “overwhelmed” and said that using the supplement had made them “more confident speaking up in class” and they did not get “as frustrated when working through tricky subjects”. We considered consumers were likely to understand those references, to the product changing or improving those symptoms, as claims that the ShroomIQ supplement could help alleviate symptoms of ADHD and anxiety.
The “Meet the Experts” section, which included an “ADHD & Cognitive Development Specialist” and stated the formula could support “neurodivergent children”, “especially in focus, mood regulation, and attention span”, further reinforced the impression that the product could help with symptoms associated with ADHD. In addition, we considered the National Library of Medicine Studies page, which referenced research relating to ingredients found in the product and their effect on ADHD, Tourette Syndrome, anxiety and depression, and referred to effects on neurological function, mood, attention, emotional balance, behaviour and memory, further contributed to the impression that the product could alleviate symptoms of ADHD and anxiety, as well as of Tourette Syndrome and depression. Although the page stated “These studies are not specific to our product. We do not claim the same results” and the homepage included, “Based on individual experiences. Results may vary”, we considered those qualifications were not sufficient to remove the impression created by the specific references to ADHD, Tourette Syndrome, anxiety and depression and their symptoms.
Claims to relieve symptoms, or to cure, or provide a remedy or heal a specific health condition or adverse condition of body or mind were regarded as medicinal claims. Given the context of the reference to ADHD and neurodivergent children, as well as Tourette Syndrome, anxiety and depression referenced on the homepage and the National Library of Medicine Studies page, we considered the claims referenced above in the customer testimonials, expert references and medical studies amounted to medicinal claims and that, as a result, the product would be understood by consumers as medicinal by its presentation.
ShroomIQ’s product was, in general terms, marketed as a food supplement. For the purposes of the legislation reflected in the Code, claims that a food (including food supplements), could prevent, treat, or cure symptoms of human disease were prohibited. We considered the claims to alleviate symptoms of ADHD, Tourette Syndrome, anxiety and depression fell under that prohibition. Additionally, because the ad made medicinal claims for ShroomIQ’s supplement, it was defined as a medicinal product for the purposes of medicines legislation. Claims that a product had medicinal properties could only be made for a medicinal product that was authorised by the MHRA or under the auspices of the EMA. We understood ShroomIQ did not hold such authorisation for their supplement.
We acknowledged that ShroomIQ said they had removed all explicit references to ADHD, Tourette Syndrome, anxiety and depression from their advertising, however, for the reasons stated, we concluded that ad (a) was in breach of the Code’s requirements relating both to food supplements and to medicinal products.
On that point, ad (a) breached CAP Code (Edition 12) rules 12.1, 12.11 (Medicines, medical devices, health-related products and beauty products), 15.6 and 15.6.2 (Food, food supplements and associated health or nutrition claims).
2. Upheld
The CAP Code defined health claims as those that stated, suggested or implied a relationship between a food or ingredient, and health, and required that only health claims authorised on the applicable register, which in this case was the Great Britain nutrition and health claims register (the GB (NHC) Register), were permitted in marketing communications for foods. Some flexibility could be exercised in rewording authorised claims, provided that the reworded claim was likely to have the same meaning for consumers as the authorised claim. Marketers had to also ensure that they met the conditions of use associated with the claims in question.
As referenced above, we considered that in the context of the references to neurodivergence, ADHD, Tourette syndrome, anxiety and depression in ad (a), claims including “Daily Focus Support” and support for “normal cognitive function” in ad (a) as well as claims that the product provided “brain support” and supported “calm, mood and confidence” in ad (b), were likely to be understood by most consumers as claims that the supplement could help manage or alleviate symptoms associated with neurodivergence, ADHD, Tourette syndrome, anxiety and depression, which were not permitted.
However, some consumers may have understood the above claims as not specifically relating to symptoms of ADHD, Tourette syndrome, anxiety and depression and might instead have interpreted them to mean that the ShroomIQ supplement could, for all children, increase focus, cognitive function, calmness, mood and confidence. In that context, those claims were specific health claims, because they related to beneficial effects on particular physiological functions.
We understood the product contained a range of vitamins and minerals in quantities that meant authorised health claims could be used in its advertising. However, we considered that the specific health claims in the ads would not have the same meaning for consumers as the authorised claims. We considered the claims in the ads went beyond the meaning of the authorised claims. For example, claims that the product provided “brain support” for children and supported “calm, mood and confidence” went beyond authorised claims such as that zinc “contributes to normal cognitive function”, by implying a broader or enhanced effect on cognitive performance, focus and mood levels. We also noted that claims were made in relation to ingredients such as Lion’s Mane, Reishi, Saffron and L-theanine, on the National Library of Medicine Studies page in ad (a), for which there were no authorised health claims on the GB (NHC) Register. Additionally, some of the claims in the ads were attributed to the supplement as a whole, rather than to the specific nutrients named in the authorised claims.
Because ads (a) and (b) included claims that were likely to be understood by some consumers as specific health claims, and these did not communicate the same meaning as the authorised claims associated with the specific nutrients mentioned, we concluded the ads breached the Code in that regard.
On that point, ads (a) and (b) breached CAP Code (Edition 12) rules 15.1, 15.1.1 (Food, food supplements and associated health or nutrition claims) and 15.7 (Food supplements and other vitamins and minerals).
3. Upheld
The CAP Code stated that ads for food products were prohibited from making health claims that referred to the recommendation of an individual health professional. In addition, it prohibited marketers from using health professionals to endorse medicines.
We noted the website homepage in ad (a) included a section headed “Meet the Experts Behind ShroomIQ”, which featured named individuals alongside their images, professional titles and quotes about the product and its benefits. We considered consumers were likely to interpret that presentation as indicating the product was developed and endorsed by those individuals. Several of the individuals featured were presented with the title “Dr”, with descriptions of their roles including “ADHD & Cognitive Development Specialist” and were therefore likely to be understood by consumers as genuine health professionals. It stated that one of the doctors “Advised on how the formula could support neurodivergent children, especially in focus, mood regulation, and attention span”.
We noted that ad (a) included a disclaimer at the bottom of the homepage, which stated “Some images, including product visuals, names and people shown, are AI-generated representations used for illustrative and branding purposes only”, which suggested the individuals shown may not be genuine health professionals.
Nevertheless, we considered that, irrespective of any specific claims made within individual testimonials or expert quotes, the inclusion of individuals presented as health professionals alongside broader claims about the product’s effects on the website homepage (as set out in points 1 and 2 above) created the overall impression that those health professionals endorsed the claimed health benefits of the product. In that context, consumers were likely to understand the ad as presenting health and medicinal claims supported by the recommendation of those individuals.
We acknowledged that ShroomIQ had said they had removed all health professional endorsements from their advertising, however, for the reasons stated, we concluded the “Meet the Experts” content in ad (a) breached the Code’s requirements for use of health professionals in relation to both food supplements and medicinal products.
On that point, ad (a) breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.9 (Qualifications), 12.18 (Medicines, medical devices, health-related products and beauty products) and 15.6.3 (Food, food supplements and associated health or nutrition claims).
Action
The ads must not appear again in their current form. We told Birling Shore Ltd t/a ShroomIQ not to state or imply that their food supplements could prevent, treat or cure human disease, which included claims to treat or cure the symptoms of ADHD, Tourette Syndrome, anxiety and depression. We also told them not to make medicinal claims for products that were not authorised by the MHRA. We further told them to ensure any specific health claims were authorised on the GB (NHC) Register, that any rewording of the authorised claim communicated the same meaning to consumers and referred to the nutrient or substance for which the claim was authorised. We also told them not to make health claims for ingredients for which there were no authorised claims. We additionally told ShroomIQ not to include health professionals or individuals presented as health professionals to endorse the product, and not to make health or medicinal claims that referred to the recommendation of an individual health professional.
CAP Code (Edition 12)
12.1 12.11 15.6 15.6.2 15.1 15.1.1 15.7 3.1 3.9 12.18 15.6.3
