A TikTok post on Aimee Crowder’s account @thissinglemamaofficial promoting Plumpit! No Needles Lip Filler Kit, seen in June 2023, featured a video of her using the product. She stated, “It comes with two products. The volumising one which is for instant plumpage, and the hyaluronic one … if you use it regularly enough, it’s gonna give you more long-term results.” In the comments section, Plumpit! Stated, “We can confirm that our Hyaluronic Lip Plumper creates long term plumping results by naturally improving collagen production”.
IssueFour complainants challenged whether the ad exaggerated the efficacy of the Hyaluronic Lip Plumper by claiming it could provide “long-term results”.
D&A Cosmetics Ltd t/a Plump It! told us that the Hyaluronic Lip Plumper was formulated with an active ingredient called Volulip™ which was tested by the manufacturer, Sederma. They provided a document with the results of the testing.
The document showed that the testing was completed on 29 females who each completed a twice daily application of a balm containing 1% Volulip™, for a month. The testing found that 97% of volunteers had an increase in the surface of the central area of the lower lip, and 69% of participants had an increase in lip volume, with an average 15.1% increase in volume. There were also positive results regarding lip softness, firmness, absorption, tissue density and hydration. The testing also concluded that after 30 days of usage, there was an increase in collagen production, moisture molecules and dermal-epidermal junction molecules in the lips.
Plump It! told us that the testing showed that after using the balm every day for a month, there was a large increase in the synthesis of collagen in the lips, and this increased lip volume. The document stated that the increase in collagen production and lip volume was the effect of Volulip™, and Plump It! believed the results demonstrated that there were long-term effects of using the Hyaluronic Lip Plumper.
In the ad, Aimee Crowder stated, “… and the hyaluronic one … if you use it regularly enough, it’s gonna give you more long-term results”, and Plump It! commented “our Hyaluronic Lip Plumper creates long term plumping results by naturally improving collagen production”. The ASA considered that consumers would understand from the claims that regular use of Hyaluronic Lip Plumper would give increased volume for an unspecified period of time after the product was used. In addition, the claim “naturally improving collagen production” implied that the Hyaluronic Lip Plumper would have a physiological, rather than a cosmetic effect. A high-level body of relevant evidence was, therefore, needed to evidence the claims in the ad.
We acknowledged the positive results outlined in the test provided by Plump It!. However, it appeared that the testing, which ended after one month, did not determine if the claimed effects continued after participants stopped using the balm. We therefore considered that the testing did not demonstrate that the effects of the balm extended beyond the application period.
Further to that while the data suggested positive results, it had not been peer reviewed, there was no control group and the testing did not use the Hyaluronic Lip Plumper but a different balm containing 1% Volulip™. The data therefore was insufficiently robust to be used as evidence for the product having a physiological effect.
For those reasons, we considered that the evidence provided by Plump It! did not sufficiently substantiate claims for the Hyaluronic Lip Plumper to have a long-term effect. In addition, claims for the product to have a physiological effect by naturally improving collagen production had not been evidenced. We therefore concluded that the ad was likely to mislead.The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation), 3.11 (Exaggeration), and 12.1 (Medicines, medical devices, health-related products and beauty products).
The ad must not appear again in the form complained about. We told D&A Cosmetics Ltd t/a Plumpit! to ensure that future ads did not make efficacy claims about the Hyaluronic Lip Plumper unless they held adequate documentary evidence to substantiate them.