The website for Friction Free Shaving Ltd, www.ffs.co.uk, a women’s razor subscription service, seen in July 2019 displayed the company’s logo, FFS, next to the name “Friction Free Shaving” in the top left-hand corner. A page titled “Here’s how we work” provided information about ordering, delivery times and how refills were delivered. Text under a drawing of a woman’s leg stated “Experience the revolution … Join over 30,000 women living life friction free, with no commitment”.
IssueProcter & Gamble, who understood that friction when shaving could not be reduced to zero, challenged whether the claim “friction free” was misleading.
ResponseFriction Free Shaving Ltd said that they intended for the phrase “friction free” to refer to the ease with which consumers could purchase their products, namely to take the stress and “friction” out of the process of shopping for shaving products. They explained that this was because consumers could purchase products online anytime and have them delivered directly to them. Friction Free Shaving said that it was not possible for a razor to provide a friction-free shave. They believed it was unlikely that a consumer would understand that the claim implied that they could achieve a friction-free shave by using their products, but if they did, consumers would assume the claim to be obvious exaggeration and would not take it literally.
AssessmentUpheld The ASA understood that Friction Free Shaving intended the claim “friction free” to be interpreted as a reference to the ease of use of their service and not as a literal statement about the efficacy of their products. However, we considered that, in the context of an ad for shaving products, consumers were likely to understand the claim “Friction Free Shaving” in the name of the company at the top of the home page and again in the claim “Join 30,000 women living life friction free” on the “About us” page as objective claims that Friction Free Shaving’s products would result in a shave which would be completely free from friction and without the negative aspects of shaving, such as irritation to the skin, shaving rash and cuts. We concluded that, because the ad claimed the advertiser’s products were able to shave completely without friction when that was not the case, the ad was misleading. The ad breached CAP Code (Edition 12) rules 3.1 3.1 Advertisements must not materially mislead or be likely to do so. and 3.2 3.2 Advertisements must not mislead consumers by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that consumers need in context to make informed decisions about whether or how to buy a product or service. Whether the omission or presentation of material information is likely to mislead consumers depends on the context, the medium and, if the medium of the advertisement is constrained by time or space, the measures that the advertiser takes to make that information available to consumers by other means. (Misleading Advertising), and 3.11 3.11 Qualifications must be presented clearly.
BCAP has published guidance on superimposed text to help television broadcasters ensure compliance with rule 3.1 3.1 Advertisements must not materially mislead or be likely to do so. . The guidance is available at:
Use of superimposed text in television advertising (Exaggeration).
The claim must not appear again in its current form. We told Friction Free Shaving Ltd not to use the claim “friction free” in relation to the efficacy of their shaving products.