Summary of Council Decision:

Two issues were investigated, both of which were Not upheld.

Ad description

Two paid-for Facebook ads for Hell Bunny, an online clothes retailer:

a. A paid-for Facebook ad, seen on 26 August 2021, featured a model wearing a green striped blouse and a black skirt.

b. A paid-for Facebook ad, seen on 30 September 2021, featured the same model wearing a long black dress and black boots.


1. The complainant, who believed the featured model appeared unhealthily thin in ad (a), challenged whether the ad was irresponsible.

2. The ASA challenged whether ad (b) was irresponsible, for the same reason.


1. & 2. Popsoda Ltd t/a Hell Bunny said that no photo editing was used in the shots and that their website and social media showed women of all sizes and body shapes to make the brand more relatable. They said there was a large proportion of people who had naturally small frames or who struggled to put on weight. They said that the model was a size XS and was within the range of standard sizing internationally. They believed that the model was a healthy individual with a normal eating pattern, and that using her complied with the codes of conduct set out by the ASA.

Facebook said they had no comments but if the complainant believed the ad was in violation of their policies they could report it to them via their standard reporting channels.


1. & 2. Not upheld

The ASA acknowledged that the model was slim, and her pose and the style of the clothing in ad (a) – a flared skirt and shirt which was tucked in at the waist, with puff sleeves and a large bow at the neck – emphasised the slenderness of her arm, neck and waist. In ad (b) she was posed leaning slightly back with one leg forward, which drew attention to the slimness of her waist. Her chin was tilted up and she was wearing a chunky necklace, which also emphasised the slenderness of her neck. However, we considered that in both ads her face, arms and neck appeared to be in proportion to the rest of her body, and she did not seem gaunt or unwell. Overall, we considered that, although the model was slim, she did not appear to be unhealthily thin or significantly underweight in either ad and therefore concluded that both ads were not irresponsible.

We investigated ads (a) and (b) under CAP Code (Edition 12) rule 1.3 (Responsible advertising), but did not find them in breach.


No further action necessary.

CAP Code (Edition 12)


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