Background
This investigation forms part of a wider piece of work related to online ads for food supplements which claim they can help with symptoms of attention deficit hyperactivity disorder (ADHD) or autism or autism spectrum disorder (ASD). The ad was identified for investigation following intelligence gathered by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules. See also related rulings published on 10 December 2025.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A paid-for Facebook ad by Healthbio, a supplement brand, published 3 June 2025, featured an image of the product with text at the top stating, “‘[5 stars] I’m 50 and I have ADHD. One of my worst traits is that I have very poor memory. It is definitely helping.’ – Diane F”. Further text stated, “TRY RISK-FREE FOR 30 DAYS”. Text in the caption stated, “No more brain fog, low energy & drive. You’re only few drops away from entering most enhanced mental and physical state. Ever. Meet Methylene Blue. Discovered in 1876 as a textile ‘dye’ at first, it didn’t took [sic] long to notice its health elevating effects. Never heard about it? PubMed is literally packed with over 200+ studies of Methylene blue benefits: It has shown to improve: Mood. Feel sustainable uplift in mood, thanks to MB serotonin and dopamine increasing properties. Focus. Improved blood circulation and enhanced oxygen absorption in your brain sharpens your focus thought processing, and decision-making abilities. Memory. Gain amplified capacity to recall and store information. Energy. By improving mitochondrial energy production and ATP, MB delivers noticeable increase in energy. Breeze through physical challenges and rise above your baseline energy levels. Anti-oxidant. Methylene Blue functions as a robust antioxidant, battling free radicals and safeguarding your cells from oxidative damage. Anti-aging. MB has the unique ability to delay the aging of your skin by increasing cell longevity, protecting against UV exposure, and accelerating the wound healing process. Learn more about this magical supplement”.
Issue
The ASA challenged whether the ad:
- implied that the supplement could prevent, treat or cure symptoms of ADHD and aid in wound healing; and
- included specific health claims that breached the Code.
Response
1. & 2. Healthbio Ltd stated that the ad had been permanently removed and had not been used again in any form. They explained they had intended to run the ad for a short testing period, without full awareness of the implications of some of the claims made. They had reviewed their advertising processes to ensure future ads remained compliant with ASA and CAP guidance, particularly regarding health and medicinal claims.
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 He[...althcare products Regulatory Agency) or under the auspices of the EMA (European Medicines Ageny). Medicines must have a license from the MHRA or under the auspices of the EMA before they were marketed.
In the image, the ad presented a five-star customer review of Healthbio’s supplement, Methylene Blue, which stated, “‘[…] I have ADHD. One of my worst traits is that I have very poor memory. It is definitely helping […]”. The ASA considered that would be interpreted as an explicit claim that the product could help alleviate symptoms of ADHD. We noted the ad only included that one explicit reference to ADHD. However, in that context, we considered the claims in the ad’s caption that methylene blue would help with energy, brain fog, mood, focus and memory would also be interpreted by a significant proportion of consumers as references to symptoms of ADHD, and that the product could therefore help alleviate those symptoms of ADHD.
Claims to relieve symptoms, or to cure, or to 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 references to ADHD, we considered the claims referenced above were medicinal claims, and implied that the product had medicinal properties.
We also considered that the claim that methylene blue had the “unique ability to […] protect […] against UV exposure” was a medicinal claim, because it implied the product could protect against skin damage caused by UV light. The claim the product could “accelerat[e] the wound healing process” was also a medicinal claim.
Methylene blue was, in general terms, marketed as a food supplement; for example, the ad referred to it as a “magical supplement”. For the purposes of the legislation reflected in the Code, its prohibition on claims that a food (including food supplements), could prevent, treat, or cure symptoms of human disease included medicinal claims. We therefore concluded the claims to alleviate symptoms of ADHD, protect against UV damage and aid in wound healing fell under that prohibition. Additionally, because the ad made medicinal claims for methylene blue, it was defined as a medicinal product for the purposes of medicines legislation. Claims that a product had medicinal properties may only be made for a medicinal product that was authorised by the MHRA or under the auspices of the EMA. However, we understood Healthbio was unlikely to hold such authorisation for methylene blue and had not received information from Healthbio to demonstrate otherwise. We concluded the ad was therefore in breach of the Code’s requirements relating both to food supplements and to medicinal products.
On that point, the ad breached CAP Code (Edition 12) rules 12.1 and 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 must 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 ad’s reference to ADHD, the claims relating to energy, brain fog, mood, focus and memory would be understood by a significant proportion of consumers as claims that the product could help manage or treat symptoms of ADHD.
However, some consumers may have understood those claims as not specifically relating to symptoms of ADHD. Instead, those consumers would have interpreted them to mean that methylene blue could, for all consumers, boost memory, mood, energy levels and focus, because the product could increase “MB serotonin and dopamine”, and improve “blood circulation”, “oxygen absorption”, and “mitochondrial energy production and ATP”. In that context, those claims were specific health claims, because they related to beneficial health effects on specific physiological functions. We considered the claims would also be understood in that way if they had been presented in isolation and absent of the wider context of references to ADHD in the ad under investigation.
We further considered that the claim “Anti-oxidant. Methylene Blue functions as a robust antioxidant, battling free radicals and safeguarding your cells from oxidative damage”, and the claim that the product could increase “cell longevity”, were also specific health claims, which all consumers would understand as unrelated to ADHD or its symptoms.
There were no authorised health claims on the GB (NHC) Register relating to methylene blue. We had also not seen any evidence demonstrating that the product included any substances for which an authorised health claim could be made. Because the ad included claims that would be understood by some consumers as specific health claims, and we had not seen evidence that those claims were authorised, we concluded the ad also breached the Code in that regard.
On that point, the ad 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).
Action
The claims must not appear again in the form investigated. We told Healthbio Ltd to ensure their future advertising did not make claims that a food, including food supplements, could prevent, treat or cure health conditions that, for the purposes of the Code fell within the definition of human disease, for example ADHD. 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, in relation to their product or ingredients in it.
CAP Code (Edition 12)
12.1 12.11 15.1 15.1.1 15.6 15.6.2
