Background
This ruling forms part of a wider piece of work on LED facemasks for skincare that make medicinal claims. 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 also related rulings published on 5 November 2025.
Ad description
A paid-for Meta ad and a website for Project E Beauty, a retailer of hair and skincare tools, seen in May 2025:
a. The paid-for Meta ad featured a video with a man superimposed over a search-engine result that included text stating, “Quality at-home LED light therapy can also help reduce […] acne”. The man said, “LED light therapy actually has clinically proven benefits […] blue light kills acne causing bacteria.” He then appeared in front of a list which included the text “Anti-Acne”, “Eliminates acne-causing bacteria”, “reduce acnes” and “Alleviates redness from […] rosacea”. The man said, “This mask from project e beauty […] has seven different colour modes […] one for acne” and “Three minutes of blue light for reducing acne.”
b. The website www.projectebeauty.uk, included a web page featuring an image of the LumaLux Face LED therapy mask with the text “Our most advanced LED mask for deeper skin renewal – […] acne”. Other text stated, “treats acne”, “Target […] acne”, “Clear Acne” and “83% Improvement in acne lesions in 4 weeks”. Before and after images showed a woman’s forehead with and without acne, and were accompanied by the text “By Week 3, my acne had disappeared”. Further text read “use your mask to target […] acne”, “HEAL ACNE”, “Acne Healing Blue light therapy uses specific acne-targeting wavelengths to eliminate acne-causing bacteria […] while […] treating other acne biomarkers” and “Skin Repair Red, cyan and yellow light help to […] fight signs of […] rosacea”. The ad also included the text “Target acne at all its life stages […] destroy acne-causing bacteria P-acnes” and “prevent acne breakouts. Acne can damage the skin barrier, so it is important to take a reparative approach to treatment including red light therapy”.
Issue
The ASA challenged whether the ads made medicinal claims for an unauthorised product.
Response
Project E Beauty LLC said they had removed ad (a) from all platforms. They had updated the product page on their website to remove potential medical claims relating to “healing”, “treating acne” and “rosacea” from ad (b). They also said they had amended ad (b) to state that any references to acne in before/after photos and reviews were testimonials based on personal experiences.
Assessment
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. In addition, the Medical Devices Regulations 2002 required that a medical device should be registered with the MHRA before it was placed on the market in Great Britain.
Ad (a) included the claims “Quality at-home LED light therapy can also help reduce […] acne”, “blue light kills acne causing bacteria”, “Anti-Acne”, “Eliminates acne-causing bacteria”, “reduce acnes”, “Alleviates redness from […] rosacea”, “this mask from project e beauty […] has seven different colour modes […] one for acne” and “three minutes of blue light for reducing acne”. The ASA considered those were claims that the product could treat or prevent acne, a medical condition.
Ad (b) included the claims “treats acne”, “Target […] acne”, “Clear Acne”, “83% Improvement in acne lesions in 4 weeks”, “By Week 3, my acne had disappeared”, “use your mask to target […] acne”, “HEAL ACNE”, “Acne Healing Blue light therapy uses specific acne-targeting wavelengths to eliminate acne-causing bacteria […] while […] treating other acne biomarkers”, “fight signs of […] rosacea”, “Target acne at all its life stages […] destroy acne-causing bacteria P-acnes” and “prevent acne breakouts. Acne can damage the skin barrier, so it is important to take a reparative approach to treatment including red light therapy”. We considered those were claims that the product could treat or prevent acne and rosacea, both of which were medical conditions.
We considered that the ads made medicinal claims and therefore required that the product met the requirements for medical devices.
We had seen no evidence that the product was registered with the MHRA or had the appropriate conformity marking. Therefore, no medical claims could be made for the product, whether or not such claims appeared in customer testimonials. We acknowledged that Project E Beauty LLC had removed ad (a) from all platforms and had amended ad (b), however, because at the time the ads appeared they made such claims, we concluded that the ads breached the Code.
The ads breached CAP Code (Edition 12) rule 12.1 (Medicines, medical devices, health-related products and beauty products).
Action
The ads must not appear again in their current form. We told Project E Beauty LLC not to make medicinal claims for products that did not have the applicable conformity marking and were not registered with the MHRA.
