Background
Summary of Council decision:
Three issues were investigated, two of which were Upheld. The other was informally resolved after the advertiser agreed to amend their advertising.
Ad description
Two web pages on a website for GuLP-1, a food supplement company, gulp-1.com, seen on 24 September 2025.
The first web page, the homepage of the website, featured the text, “Stubborn weight gone. Guaranteed. A science-backed blend of natural fibres that helps you feel fuller for longer - supporting healthy, sustainable weight loss without injections". Further text stated, "Natural Weight Loss & Blood Sugar Support", "Stop Your Cravings", and "Natural Alternative To Trending Weight Loss Products", alongside a comparison table, which featured an image of the GuLP-1 packaging next to an injection pen.
The second web page, a listing for “Weight Loss+ Formulation”, included the text "Engineered for optimum weight loss by naturally increasing GLP-1 levels”, and "Weight: Unlock results with reduced cravings", "Energy: Prevent slumps and crashes", "Digestive: Increase GLP-1 naturally".
"Why GuLP-1? GuLP-1's prebiotic fibres work gradually in the gut, triggering a natural, steady release of GLP-1 - the body's own appetite-regulating hormone. This slow, sustained activation helps reduce cravings and supports long-lasting hunger control between meals. When taken daily, GuLP-1 can support healthy, sustainable weight loss alongside a balanced diet and regular movement."
Issue
- The complainant challenged whether the ad included health claims that complied with the Code.
- The ASA challenged whether the ad implied that the products had the same medicinal effects as GLP-1 agonist medication.
Response
1. & 2. GLP-1 Pro Ltd t/a Gulp said that Gulp relied exclusively on health claims that had been authorised on the Great Britain nutrition and health claims Register (the GB NHC Register) in relation to, its ingredients, and that their use complied with their conditions of use. Gulp provided the authorised wording used which they said appeared on both pages. They believed their product met the conditions for use.
Gulp said claims such as “Stubborn weight gone”, “Natural weight loss”, “Stop your cravings” and “Reduce hunger” were general weight-management descriptors rather than standalone health claims. They said those statements appeared on pages that also included the authorised glucomannan weight-loss claim and were framed within the context of diet and lifestyle.
Gulp said that, following receipt of the ASA’s correspondence, it removed all references to GLP-1 and related imagery, including all references to “GLP-1”, hormones, needles, injections, and comparisons to prescription medicines.
Gulp said the product name “Gulp-1” was presented as a brand name only, and no longer appeared alongside references to medicines or medicinal effects.
Assessment
1. Upheld
The CAP Code stated that health claims were only permitted in marketing communications for food or food supplements if they were authorised on the GB NHC Register. It defined health claims as those that stated, suggested or implied a relationship between a food, drink or ingredient and health.
The ASA considered the claims “Stubborn weight gone”, “Natural weight loss”, “a science-backed blend of natural fibres that helps you feel fuller for longer – supporting healthy, sustainable weight loss”, “Weight: Unlock results with reduced cravings” and “GuLP-1 can support healthy, sustainable weight loss alongside a balanced diet and regular movement”, would be understood by consumers as meaning the product was able to help them achieve weight loss. They were therefore specific health claims for the purposes of the Code.
We further considered the claims “Engineered for optimum weight loss by naturally increasing GLP-1 levels”, “Digestive: Increase GLP-1 naturally”, and “GuLP-1's prebiotic fibres work gradually in the gut, triggering a natural, steady release of GLP-1” would be interpreted to mean that the product was able to increase consumers’ production of the hormone GLP-1. They were therefore specific health claims for the purposes of the Code. We also considered that the product’s name, which was stylised as “GuLP-1”, would be understood as a specific health claim, that the product could affect GLP-1 production.
However, we had seen no evidence which demonstrated that those claims were authorised on the GB NHC Register in relation to the product or any of its ingredients.
Gulp included glucomannan, for which there was an authorised health claim on the GB NHC Register – ‘Glucomannan in the context of an energy restricted diet contributes to weight loss’ – which appeared in the small print at the bottom of the product listing. However, the main claims on the page relating to glucomannan and weight loss did not match the wording of the authorised claim. Additionally, they referred to the suppression of hunger cravings, for which there was no authorised claim.
In addition, the claim was required to be made in relation to the relevant nutrient or food for which it had been authorised, rather than for the product as a whole, whereas we considered consumers would understand the claims to relate to the effects of the product as a whole, rather than the glucomannan contained in the product. Further, we understood that the conditions of use for the authorised claim about glucomannan stated, “The claim may be used only for food which contains 1 g of glucomannan per quantified portion. In order to bear the claim information shall be given to the consumer that the beneficial effect is obtained with a daily intake of 3 g of glucomannan in three doses of 1 g each, together with 1-2 glasses of water, before meals and in the context of an energy-restricted diet.” However, the ad stated, “The maximum dose we recommend is 40g across 4 doses with 1-2 glasses of water before each. This means you get 4g of Glucomannan […] This will give you the full quoted benefit”. We understood consumers who took the supplement in accordance with the guidance in the ad would ingest 4 g of glucomannan. We therefore considered the claim did not meet the conditions of use as stated on the GB NHC Register.
For those reasons, we concluded that those specific health claims breached the Code.
On that point, the ad breached CAP Code (Edition 12) rules 15.1, 15.1.1, and 15.7 (Food, food supplements and associated health or nutrition claims).
2. Upheld
The CAP Code stated that claims which stated or implied a food could prevent, treat or cure human disease were prohibited for foods, including food supplements. It also stated that medicinal claims may be made for a medicinal product that was authorised by the MHRA (Medicines and Healthcare products Regulatory Agency) or under the auspices of the EMA (European Medicines Agency). Medicines must have an authorisation from the MHRA or under the auspices of the EMA before they were marketed.
We considered that consumers were likely to understand the references on the homepage to “sustainable weight loss without injections” and the comparison table with the image of an injection pen to mean the product was equivalent to or had similar effects to GLP-1 agonist injections, which were prescription only medicines (POM) used for weight loss. In the context of claims relating to GLP-1 agonist injections, we considered that product claims to reduce hunger or cravings would also be understood as medicinal by presentation.
We considered the following claims implied that the product had the same weight loss effects as GLP-1 agonist injections, and were therefore medicinal claims: “A science-backed blend of natural fibres that helps you feel fuller for longer - supporting healthy, sustainable weight loss without injections", "Stop Your Cravings”, and "Natural Alternative To Trending Weight Loss Products”.
The claims implied that the product, which was marketed as a food supplement, had medicinal properties. We understood that such claims were, for the purposes of the legislation reflected in the Code, prohibited claims that a food could prevent, treat or cure human disease. Additionally, because the ad made medicinal claims for the product, it was defined as a medicinal product by presentation for the purposes of the medicines legislation, reflected in the Code. However, we had not seen evidence that the advertiser held the necessary authorisation.
We acknowledged that Gulp had removed comparisons to GLP-1 agonist injections from the ad. However, because at the time it appeared, the ad implied that a food supplement could prevent, treat or cure human disease, and featured claims that a product had medicinal properties without the necessary authorisation, we concluded that it breached the Code.
On that point, the ad 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).
Action
The ad must not appear again in the form investigated. We told GLP-1 Pro Ltd t/a Gulp not to make specific health claims unless they were authorised on the GB NHC Register, including through product names. We told them not to claim that a food supplement could prevent, treat or cure human disease, or make medicinal claims for a product that did not have the necessary authorisation. That included that they must not compare the effects of a food supplement to those associated with prescription-only medicines used for weight-loss, such as GLP-1 agonist injections.
