Background
This ruling forms part of a wider piece of work on ads for food supplements making claims about the treatment of symptoms of the menopause, Polycystic Ovarian Syndrome (PCOS) and other women's hormonal issues.
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 other rulings published on 25 March 2026.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A paid-for Facebook ad and a website for Minerva Wellness, a supplement brand, seen in July 2025.
a. The paid-for Facebook ad included the heading “Your all-in-one menopause support – without HRT” “Shop now and feel the difference” and showed an image of the product with the caption “Feel Like You Again With 2 Capsules Daily”. Alongside the image was a screenshot of a review which showed 5 stars, and text which stated, “I can’t believe how much better I have been feeling generally since I started taking these supplements […] better sleep quality”. Text in a caption stated, “Say goodbye to hot flashes” ‘[sic]’ [flame and snowflake emojis].
(b). The website www.minervawellness.com, featured the headline “Get your edge back. Award-winning Natural Menopause Relief. Supports Hormonal Balance and Metabolism”.
Further down the page, next to an image of a bottle of Minerva Reset supplement, text stated: “Tried & Tested probiotic supplements for menopause”; “Minerva Reset is an all-in-one natural menopause supplement containing four of the best probiotics for menopause as well as 16 concentrated plant botanicals, trace minerals, adaptogenic herbs, vitamins and phytoestrogens – weaker plant-based oestrogens”; and “Minerva Reset helps support hormonal balance, cognitive and physiological functions […] anxiety, low mood, fatigue, bloating, sleep, hot flushes, sluggish metabolism, night sweats and skin”.
Issue
The ASA challenged whether the claims:
- that stated or implied that the supplements, or substances in them, could help to prevent, treat or cure the symptoms of the menopause and perimenopause, breached the Code; and
- “adaptogenic herbs” in ad (b) was a specific health claim which breached the Code.
Response
Minerva Wellness Ltd t/a Minerva Wellness did not respond to the ASA’s enquiries.
Assessment
The ASA was concerned by Minerva Wellness’ lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay). We reminded them of their responsibility to provide a response to our enquiries and told them to do so in the future.
1. Upheld
The CAP Code (which reflected legislation) 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 licensed by the MHRA (Medicines and Healthcare products Regulatory Agency) or under the auspices of the EMA (European Medicines Agency). Medicines must have a license from the MHRA or under the auspices of the EMA before they were marketed.
Ad (a) stated, “Your all-in-one menopause support – without HRT”. HRT (Hormone Replacement Therapy) was a commonly known prescription-only medicine (POM) used as a treatment for the alleviation of symptoms of the menopause. We considered consumers would understand the claim to mean that the product could be taken as an alternative to HRT and that it would have the same effect as HRT in treating menopause symptoms. We therefore considered that was a medicinal claim.
Ad (a) also stated, “Feel Like You Again With 2 Capsules Daily”, “Say goodbye to hot flashes” and a testimonial from a customer –“I can’t believe how much better I have been feeling generally since I started taking these supplements [...] better sleep quality”. We considered that in the context of an ad that made reference to HRT, and consequentially made a comparison with POMs used for symptoms of the menopause, those claims were also medicinal claims.
The claims therefore implied that the product, which was marketed as a food supplement, had medicinal properties. 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 also considered that those claims stated or implied that the product could treat or cure various hormonal symptoms associated with the menopause. We further considered that symptoms of the menopause were adverse medical conditions. Because of that, we considered the claims that the supplement could treat or cure symptoms of the menopause, both in general terms and in relation to specifically described symptoms, were for the purposes of the legislation reflected in the Code, claims to treat disease.
Ad (b) stated, “Natural Menopause Relief. Supports Hormonal Balance and Metabolism”, “supplements for menopause”, “all-in-one natural menopause supplement” and “helps support hormonal balance, cognitive and physiological functions […] anxiety, low mood, fatigue, bloating, sleep, hot flushes, sluggish metabolism, night sweats and skin […]”. We considered that those claims stated or implied that the product could treat or cure various hormonal symptoms associated with the menopause, which as stated above, were adverse medical conditions. Because of that, we considered the claims in ad (b), that the supplement could treat or cure symptoms of the menopause, both in general terms and in relation to specifically described symptoms, were for the purposes of the legislation reflected in the Code, claims to treat disease.
For those reasons, we concluded that ads (a) and (b) made claims that a food supplement could prevent, treat or cure human disease and therefore breached the Code. We also concluded that ad (a) featured claims that a product had medicinal properties without the necessary authorisation and also breached the Code on that basis.
On that point, ads (a) and (b) breached CAP Code (Edition 12) rules 15.6 and 15.6.2 (Food, food supplements and associated health or nutrition claims). Ad (a) also breached CAP Code (Edition 12) rules 12.1 and 12.11 (Medicines, medical devices health-related products and beauty products).
2. Upheld
The CAP Code required that only health claims authorised on the Great Britain nutrition and health claims Register (GB NHC Register) were permitted in marketing communications for foods. The Code defined health claims as those that stated, suggested or implied a relationship between a food, drink or ingredient and health.
Ad (b) included the claim “adaptogenic herbs” and we considered that some consumers may not be familiar with this term “adaptogenic”. However, we understood the term was used to describe natural substances believed to help the body respond to stress, and we considered many consumers who were interested in food supplements, and their potential health benefits, would have some knowledge of that definition. We therefore considered the claim “adaptogenic herbs” would be understood to mean that the product contained herbs that supported the body’s ability to respond to stress, which we considered was a specific health claim for the purposes of the Code. We had not, however, seen any evidence which demonstrated that the claim was authorised on the GB NHC Register. Because of that, we concluded that it was an unauthorised health claim and therefore breached the Code.
On that point, ad (b) breached CAP Code (Edition 12) rules 15.1 and 15.1.1 (Food, food supplements and associated health or nutrition claims).
Action
The ads must not appear again in the forms investigated. We told Minerva Wellness Ltd t/a Minerva Wellness not to state or imply their food supplements could prevent, treat or cure human disease, which for the purposes of the Code included claims to treat or cure the symptoms of the menopause, or make medicinal claims for a product that did not have the necessary authorisation. We also told them not to make specific health claims unless they were authorised on the GB NHC Register. We referred the matter to CAP’s Compliance team.
CAP Code (Edition 12)
1.7 12.1 12.11 15.1 15.1.1 15.6 15.6.2
