Ad description
A Video-On-Demand ad for Garnier Vitamin Cg Serum, seen on 28 October 2025, featured a model holding a pack of the product to camera and then using it on her skin. It showed a close-up of a dark spot on her face highlighted by computer graphics. Alongside that, the voice-over stated, “Dark spots? Take one brighter step with new Garnier Vitamin Cg Serum. Now with a 4% active concentration, clinically proven to reduce hyperpigmentation in 2 weeks. 99% agree skin is glowing. New Garnier Vitamin Cg Serum. No wonder it’s the UK’s number one. By Garnier, naturally.” Text on screen stated “4% VITAMIN Cg NIACINAMIDE SALICYCLIC ACID MELASYL™”; “CLINICALLY PROVEN TO REDUCE HYPERPIGMENTATION IN 2 WEEKS**”; and “5% VITAMIN CG NIACINAMIDE SALICYLIC ACID MELASYL”. Small text at the bottom of the screen throughout most of the ad stated, “** 72% of 111 women agree. Clinical study, 44 subjects 10 weeks”.
Issue
The complainant challenged whether the claim “clinically proven to reduce hyperpigmentation in 2 weeks” was misleading and could be substantiated.
Response
L’Oréal (UK) Ltd t/a Garnier said that the qualification in the ad was, by error, inaccurate. The ad had shown “**72% of 111 women agree, clinical study, 44 subjects, 10 weeks”, but the correct qualifier for that claim should have been “**Clinical study, 44 subjects, 10 weeks”. They said the error could have led to consumer confusion between subjective and objective claims, and that the qualifier would not appear in its current form in future communications.
They stated that the product formulation contained niacinamide, ascorbyl glucoside (Vitamin Cg) and Melasyl (a patented molecule), which were known for their anti-pigmentation effects. Ascorbyl glucoside (Vitamin Cg) acted as a stable precursor to Vitamin C, providing sustained antioxidant protection and tyrosinase inhibition (tyrosinase inhibitors blocked the enzyme responsible for producing melatonin to reduce hyperpigmentation), whilst niacinamide worked by inhibiting the melanosome transfer (melanosomes were pigment-producing organelles). Melasyl worked by “capturing” melanin precursors. Garnier provided a clinical study to substantiate the claim “clinically proven to reduce hyperpigmentation in 2 weeks”, and a published paper on Melasyl.
Assessment
Upheld
The CAP Code stated that before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers were likely to regard as objective and that were capable of objective substantiation. Objective claims must be backed by evidence, if relevant consisting of trials conducted on people.
The ad showed a woman outdoors wearing summer clothing. It showed a close-up of her face with a brown spot on her cheek and, at the same time, a voice-over stated, “Dark spots?”. Later in the ad, the voice-over stated, “Clinically proven to reduce hyperpigmentation in two weeks”, whilst the same claim appeared on screen. We considered viewers were likely to understand the claim to mean that the product was proven to significantly reduce the visible appearance of dark spots and hyperpigmentation of the skin within two weeks. We therefore expected to see evidence to demonstrate that was the case.
We noted Garnier’s comments that they had erroneously included the qualification “**72% of 111 women agree” alongside the intended qualification “Clinical study, 44 subjects, 10 weeks”. However, we did not consider that the first qualification changed the overall understanding of the claim “clinically proven to reduce hyperpigmentation in 2 weeks”, as outlined above. We therefore assessed the ad on the basis of the evidence provided to us, and that the qualification should have appeared as intended in the ad, specifically: “**Clinical study, 44 subjects, 10 weeks”.
We assessed the evidence provided, which included an unpublished clinical trial and a published paper on the ingredient Melasyl. Garnier requested that we treat the specific details of the clinical trial as confidential, because it contained commercially sensitive information.
We understood that the clinical trial looked at the effects of twice daily use of the serum on dark spots for 10 weeks to assess the product’s anti-pigmentation effects. We acknowledged that the clinical trial used a device which objectively measured the appearance of dark spots at baseline, two weeks and 10 weeks after following the regime, and compared the results to a control group. However, we considered there were limitations, including that the sample size was small, and there was no evidence in the trial report provided to support whether the sample size used was big enough to be clinically robust. Additionally, we had concerns about the methodology of the trial, including that the report did not set out the randomisation method in a way which allowed us to understand how the assignment of participants to the treatment and control groups had been carried out.
Finally, we considered the relevance of the trial conditions to typical UK use. We understood that the trial was conducted in a country with a hotter, sunnier climate than the UK and different participant characteristics in terms of skin type. We acknowledged that Garnier had included the spectrum of skin types of the Fitzpatrick scale, a numerical classification system from I to VI developed to measure a skin’s pigment and reaction to UV light. However, we noted that the distribution of the different skin types in participants in the trial was different from the distribution of skin types we would expect to see in the UK, and therefore may not have been representative of UK skin types. The trial also included protocol requirements intended to limit UV exposure and standardise conditions, including the avoidance of sun or artificial UV exposure and use of SPF products. We noted that the model in the ad was seen outside in bright conditions, and we considered that the conditions in the study were not reflective of how consumers would have understood that the product needed to be used from the ad. We considered that those factors, alongside differences that could arise from climate and participant characteristics, reduced the extent to which the results could be taken as directly representative of typical use by UK consumers in everyday conditions.
Notwithstanding the above limitations, we considered that, whilst the results showed some statistically significant differences in the treatment group after two weeks, the reported percentage changes were small, and were only seen amongst a minority of subjects. In addition, whilst we also noted that 82% of participants in the clinical study agreed that their dark spots looked less visible after 2 weeks, we considered this to be a subjective, self-reported result which was not adequate to substantiate a “clinically proven” claim.
We therefore considered that the clinical trial was not sufficiently robust to substantiate the claim “clinically proven to reduce hyperpigmentation in 2 weeks”.
We also considered the published paper on Melasyl, which was a placebo-controlled, randomised study that looked at three products containing 2-MNG (L’Oreal’s patented molecule: Melasyl) in 35 people whilst being exposed to UV light. However, we understood that the study was designed to assess the efficacy of the molecule in preventing pigmentation caused by controlled UV exposure in healthy skin, not treatment of established hyperpigmentation. We therefore did not consider it was relevant to substantiate the claim.
For the reasons outlined, we considered that the evidence was not adequate to substantiate the claim “clinically proven to reduce hyperpigmentation in 2 weeks”, and we therefore concluded that the claim was misleading.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 12.1 (Medicines, medical devices, health-related products and beauty products).
Action
The ad should not appear again in the form complained of. We told L’Oréal (UK) Ltd t/a Garnier not to state or imply that Garnier Vitamin Cg Serum was clinically proven to reduce hyperpigmentation in two weeks unless they held robust evidence to substantiate their claim.
