Background
Summary of Council decision:
Three issues were investigated, all of which were Upheld.
Ad description
A paid-for Facebook ad for Healthy Dog 24/7, seen on 22 April 2026, promoted NutriPaw’s Dental Powder, a dog dental care product, displayed text that stated, “Bad Breath […] the dental range makes it simple” and featured an embedded video that opened with text and narration that stated, “If you've ever signed a form that lists death as a risk of anaesthesia [sic] just to get your dog's teeth cleaned, drop everything and listen.” The ad was narrated in the first person by a woman wearing vet clothing who stated, “After 14 years as a veterinary dental specialist”.
The narration, accompanied by on-screen text stated, “There are three lies every dog owner believes that are literally killing their pets. Lie number one, anaesthesia is routine and perfectly safe […] healthy dogs go under for a tooth cleaning and never wake up. […] Lie #2 Professional cleaning is the only way to remove tartar. This is the most profitable lie in veterinary medicine. The science exists to break it down safely at home. They just don’t want you to know.” The ad also stated, “Three dogs same month, all routine cleanings, all healthy screenings, all dead”, and “One in 1,000 healthy dogs die under anaesthesia. For senior dogs, higher. For dogs with heart murmurs, higher still. And they’re dying for a teeth cleaning”.
The ad also stated, “you’re trapped between two impossible choices. Sign the waiver, say the goodbye, hope your dog wakes up […] or do nothing. Watch bacteria spread from their mouth into their bloodstream. Watch their organs fail slowly. Both options feel like killing your dog.”
The ad further stated, “I found Dr. Rachel Chen veterinary dental specialist […] she spent two years developing an enzymatic formula that breaks down tartar cement at the molecular level for conscious, non-sedated dogs” and, “I tested it on a 10-year-old beagle […] severe tartar. Heart murmur […] anaesthesia was too risky […] day three […] the brown cement edges were starting to soften. Day seven, a chunk of tartar literally fell off while he was eating […] Day 21, his teeth looked cleaner than they had in five years”.
It also stated, “I ran a real trial. 47 dogs […] 90 days later, 43 showed dramatic tartar reduction. 18 dogs too old for anaesthesia got clean teeth for the first time in years […] at-home powder that uses natural enzymes to shatter calcified tartar at the molecular level […] without risking your dog's life. How it works? Kelp enzymes penetrate the tartar element and break the calcium bonds […] spirulina seals the microscopic gaps in gums, leaky gums […] peppermint kills the bacteria […] stopping sulpfur [sic] that create the death breath smell. One scoop in their food […] NutriPaw's dental powder is the only way to get professional-grade tartar breakdown without playing anaesthesia roulette.”
Montage imagery, throughout the ad accompanied the narration, showed owners with dogs, individuals visibly upset and individuals being physically sick as well as dogs undergoing veterinary procedures, including anaesthetic, dental treatment, injections and CPR. The ad also showed mouths and teeth of multiple dogs with severe plaque and tartar, that were brown and yellow in colour; then later imagery of mouths of other dogs with clean, white teeth.
Issue
The complainant challenged whether:
- the ad misleadingly and irresponsibly implied dogs undergoing veterinary treatment had a higher chance of dying;
- the ad made medicinal claims for an unauthorised product; and
- the efficacy claims for NutriPaw’s Dental Powder were misleading.
Response
NutriPaw Ltd t/a Healthy Dog apologised, said the ad had been removed and would not be used again. They explained that they had improved their advertising approval process to ensure similar issues did not occur in the future.
Assessment
1. Upheld
The ASA considered consumers would understand the claims “There are three lies every dog owner believes that are literally killing their pets. Lie number one, anaesthesia is routine and perfectly safe […] healthy dogs go under for a tooth cleaning and never wake up”, “Three dogs same month, all routine cleanings, all healthy screenings, all dead”, “One in 1,000 healthy dogs die under anaesthesia” and “they’re dying for a teeth cleaning” to mean that routine veterinary dental procedures involving anaesthesia carried a significant risk of death, including for otherwise healthy dogs. We considered that impression was reinforced by imagery showing dogs undergoing anaesthetic and dental procedures followed by other imagery of dogs that had died and undergoing CPR.
We also considered consumers would understand the claims “Professional cleaning is the only way to remove tartar. This is the most profitable lie in veterinary medicine. The science exists to break it down safely at home. They just don’t want you to know” to mean that professional veterinary dental treatment was not necessary because tartar could be treated safely at home, and that this treatment option was not shared by vets because of a financial motivation. In the context of the ad, we considered consumers would understand that to mean the advertised product was a suitable and safer alternative to traditional veterinary dental treatment for dogs.
Because the ad made specific mortality claims and gave the overall impression that routine veterinary dental procedures involving anaesthesia carried a significant risk of death, we considered robust evidence was required to substantiate those claims. However, no such evidence was provided.
We also considered that the ad presented professional veterinary treatment as carrying a significant risk of death, that tartar could be treated safely at home, and suggested vets were driven by financial motivation. In that context, we considered the ad was likely to discourage owners from seeking appropriate veterinary treatment for their dogs.
We understood that, in cases of significant tartar or dental disease, treatment to prevent pain, disease progression or other harm required professional veterinary intervention and we considered discouraging that treatment
was irresponsible.
For those reasons, we concluded the ad misleadingly and irresponsibly implied that dogs undergoing veterinary dental treatment involving anaesthesia faced a significant risk of death.
On that point, the ad breached CAP Code (Edition 12) rules 1.3 (Social responsibility), 3.1 (Misleading advertising) and 3.7 (Substantiation).
2. Upheld
The CAP Code stated that 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.
We understood from the VMD that the claim “Do nothing. Watch bacteria spread from their mouth into their bloodstream. Watch their organs fail slowly. Both options feel like killing your dog”, in the context of preventing infection from spreading through the body and causing organ failure that could be fatal, was a medicinal claim.
We also understood that NutriPaw’s Dental Powder was not licensed by the VMD for that purpose.
Because the ad made a medicinal claim for an unauthorised product, we concluded that it breached the Code.
On that point, the ad breached CAP Code (Edition 12) rule 12.11 (Medicines, medical devices, health-related products and beauty products).
3. Upheld
The ASA considered consumers would understand the claims “breaks down tartar cement at the molecular level”, “shatter calcified tartar”, “90 days later, 43 showed dramatic tartar reduction” and “clean teeth for the first time in years” to mean that NutriPaw’s Dental Powder was effective at removing tartar and delivering significant improvements in dogs’ dental health. Further, within the context of the ad, the claim “Professional cleaning is the only way to remove tartar. This is the most profitable lie in veterinary medicine. The science exists to break it down safely at home” was likely to be understood to mean that the product offered results equivalent to professional veterinary dental cleaning.
We also considered consumers would understand the claims “I ran a real trial. 47 dogs”, “Day seven, a chunk of tartar literally fell off while he was eating” and “43 showed dramatic tartar reduction” to mean that those efficacy claims were supported by evidence.
Furthermore, we considered the visual presentation of imagery that showed dogs’ mouths with severe plaque and tartar followed by imagery of clean, white teeth further reinforced the efficacy claims made throughout the ad.
Because the ad made objective claims about the product’s efficacy, including references to what consumers would understand to be trial results, we considered the advertiser would need to hold robust evidence to substantiate those claims. However, NutriPaw had not provided any evidence. We therefore considered that the efficacy claims had not been substantiated and were misleading.
For those reasons, we concluded that the efficacy claims for NutriPaw’s Dental Powder were misleading.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation).
Action
The ad must not appear again in the form complained about. We told NutriPaw Ltd t/a Healthy Dog to not make efficacy claims unless they held adequate, robust evidence and not to make medicinal claims for an unauthorised product. We also told them not to misleadingly and irresponsibly imply dogs undergoing veterinary treatment had a higher chance of dying.
