Background
This ruling forms part of a wider piece of work on LED facemasks for skincare that make medicinal claims. 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 5 November 2025.
Ad description
A paid-for Meta ad and a website for Silk’n, a retailer of hair and skincare tools, seen on 20 May 2025:
a. The paid-for Meta ad featured a video of a woman using an LED face mask with the caption: “[…] Finished with the blue light to help treat my acne and scars".
b. The website www.silkn.co.uk, included a webpage with an image of an LED face mask. Under an image of a woman using the remote control to administer treatment, text stated, “Targeted acne-related treatment […] precise and targeted treatment to effectively reduce acne-related redness”.
Issue
The ASA challenged whether the ads made medicinal claims for an unauthorised product.
Response
Invention Works BV t/a Silk’n said ad (a) was created by a user of the product based on her experience after prolonged use. The wording reflected her individual perception and results, and she had approved the use of her testimonial for advertising. They said they always ensured user testimonials were realistic and recognised individual outcomes could be influenced by multiple factors such as diet and lifestyle.
Silk’n acknowledged that the term “acne” constituted a medical claim. For that reason, they never used “acne” in their own corporate or product communications. The word was only used when quoting consumer reviews, as in ad (a). They understood “acne-related redness” not to be a medical claim. Based on legal advice and industry guidance, they understood “acne-related redness” could be used in connection with non-medical, beauty devices. They had intended it to indicate cosmetic benefits relating to visible redness associated with blemishes, rather than the treatment of a medical condition.
Assessment
Upheld
The CAP Code stated medicinal or medical claims and indications could only be made for a medicinal product that was licensed by the Medicines and Healthcare products Regulatory Agency (MHRA), the Veterinary Medicines Directorate (VMD) or under the auspices of the European Medicines Agency (EMA), or for a medical device with the applicable conformity marking. In addition, the Medical Devices Regulations 2002 required that a medical device should be registered with the MHRA before it was placed on the market in Great Britain.
Ad (a) included the claim “Finished with the blue light to help treat my acne and scars”. Ad (b) included the claim “Targeted acne-related treatment […] precise and targeted treatment to effectively reduce acne-related redness”. We contacted the MHRA. They told us that in general claims to treat redness related to acne were a medicinal claim. However, MHRA reviewed products on a case-by-case basis to determine borderline claims. The ASA considered the claims in ads (a) and (b), including “reduce acne-related redness”, were claims that the product could treat or prevent acne, a medical condition.
We considered that the ads made medicinal claims and therefore required that the product met the requirements for medical devices. We had seen no evidence that the product was registered with the MHRA or had the appropriate conformity marking. Therefore, no medical claims could be made for the product, whether or not such claims appeared in customer testimonials.
The ads breached CAP Code (Edition 12) rule 12.1 (Medicines, medical devices, health-related products and beauty products).
Action
The ads must not appear again in the form investigated. We told Invention Works BV t/a Silk’n not to make medicinal claims for products that did not have the applicable conformity marking and were not registered with the MHRA.
