Ad description
Four product listings on the Zara website, seen on 5 May 2025, included images of products worn by female models:
a. The first ad featured an image of a model wearing an oversize pocket shirt.
b. The second ad featured an image of the same model in ad (a) wearing a contrasting ruffle body suit.
c. The third ad featured an image of a model wearing a voluminous combined short dress.
d. The fourth ad featured an image of a model wearing a pair of extra wide-leg high-waist jeans.
Issue
The complainant, who believed the models appeared unhealthily thin, challenged whether the ads were irresponsible.
Response
ITX UK Ltd t/a Zara said that ads (a) and (b) featured the same model, who had worked for well-known fashion brands. They said ads (c) and (d) featured the same model, who had also worked for reputable fashion brands.
Zara said that, when they hired models, they operated in line with the recommendations of ‘Fashioning a Healthy Future’, which was a report published by the UK Model Health Inquiry. Specifically, they believed they complied with ‘Recommendation Three’ of that report, which stated that models “should provide a medical certificate attesting their good health from doctors with expertise in recognising eating disorders”. Zara confirmed that both models had medical certification which proved they were in good health.
They said that none of the images had been modified, beyond very minor lighting and colouring edits. They said all four ads were part of a carousel of images published on the Zara website.
Zara confirmed that after receiving the complaint they had amended the product listings and removed the specific images in all four ads. They said they had not received any direct complaints about the ads.
Assessment
Upheld in relation to ads (a) and (c) only
The ASA considered whether, for each ad, the relevant model was depicted in such a way as to make them appear unhealthily thin. Ad (b) featured a close-up image of a model appearing to be stood up, with her body facing one way and her head slightly twisted in the other direction. We acknowledged that the model’s collarbone was visible, which likely appeared to be more prominent because of the position of her head. However, we considered the model’s face did not look gaunt and that, whilst only partially visible, her stomach, chest and arms did not display any protruding bones. In addition, her legs were not visible in the image. We therefore considered that, despite her collarbone being visible, the model’s body appeared in proportion and was not presented as unhealthily thin overall.
Ad (d) featured an image of a model stood up, with both of her legs visible. Her stomach was partially visible, as were her arms, which were straight and positioned downwards in front of her legs. We acknowledged that the model was wearing baggy jeans, which created the impression that her legs were slim. We also considered the lighting drew some attention to the bones in her hands and that, because her arms were cut off in the image, they appeared longer and slimmer than they might have been. However, we considered that the model’s body was presented as being in proportion. Her stomach, which was mostly covered by a shirt, did not look gaunt. In addition, the image featured no protruding bones. For those reasons, we considered the model was not presented as being unhealthily thin.
Ad (a) featured the same model seen in ad (b), who was standing up with her right hand on her hip and her left hand in her pocket. We considered that the low-cut design of the shirt drew attention to the model's upper chest area, creating a focal point around her collarbone, which was protruding. The styling of the image meant her collarbone appeared to run alongside the collar line of the shirt, making it a prominent feature of the image. In addition, the positioning of her arms, whilst wearing a baggy shirt, created the impression that her arms, shoulders and chest were very slim. Overall, we considered that the pose of the model and the choice of clothing in the ad created the impression that the model was unhealthily thin.
Ad (c) featured the same model seen in ad (d), who was standing up with her arms down by her side. We considered that the shadows over her legs drew attention to them whilst making them appear noticeably thin. Her hair was styled in a slicked back bun, which drew emphasis to her head whilst making it appear slightly gaunt. There was a contrast in how her upper arms and elbow joints were positioned, which made her body appear slightly out of proportion. In addition, because of the style of dress she was wearing, the model’s collarbone was visibly protruding. For those reasons, we considered that the styling, lighting of the image and the choice of clothing meant the ad created the impression that the model was unhealthily thin.
For the above reasons, we concluded that the models in ads (a) and (c) appeared unhealthily thin and that the ads were irresponsible. The ads breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
We also investigated ads (b) and (d) under CAP Code (Edition 12) rule 1.3 (Social responsibility) but did not find them in breach.
Action
Ads (a) and (c) must not appear again in the form complained about. We told ITX UK Ltd t/a Zara to ensure that the images in their ads were prepared responsibly and did not portray models as being unhealthily thin.
