Ad description

A video on demand (VOD) ad for Bare Minerals, seen on ITV Hub on 12 November 2018, featured various shots of several models, predominantly showing their head and shoulders. They were in a range of poses.


The complainant, who believed that two of the models featured appeared unhealthily thin, challenged whether the ad was irresponsible.


Shiseido UK Co Ltd t/a Bare Minerals (Bare Minerals) said they did not consider that the two models referred to by the complainant were unhealthily thin. They provided still images of the two models that were used for in-store ads, and said it was clear from those photographs that neither model was unhealthily thin.

Bare Minerals said they were a brand for make-up and cosmetics, and as a result their advertising always focused primarily on model’s faces, rather than their bodies. They highlighted that the lead actress in the ad Letitia Wright, was wearing a suit that covered her arms and torso. They said they had a policy to feature healthy looking women, and they did not use models who were unhealthily thin. Additionally, they said the message throughout the campaign was about being good to yourself and others, and good health was integral to that message. They would not, therefore, promote models who looked unhealthy in the ad.

Bare Minerals said the ad was approved by Clearcast, and they confirmed no post-production techniques had been used to alter the appearance of the models.

Bare Minerals said the ad was consistent with previous ASA rulings which had not been upheld relating to whether models were unhealthily thin. They said that in such rulings which had been upheld, those ads had featured models with prominent rib cages, very thin arms or a thigh gap. However, in their ad both models were fully dressed and their rib cages were not visible. They recognised that one of the models in question was wearing a spaghetti top which exposed her clavicle bones, but they considered that those bones were not unduly prominent and the model also had a reasonably full bust, and therefore she did not look unhealthily thin.

ITV said the ad was served on the ITV Hub and was subject to Clearcast VOD Advice. They said that although the models were slim in stature, they were not unnaturally or irresponsibly so, and it was reasonable to consider that in specific scenes in the ad, the mannerisms and posture of the models (primarily the head and shoulder shots) did not cause an impression of unnatural, irresponsible or unhealthy thinness. They also highlighted that the brand promoted itself as an ethically-aware product range.

Clearcast said the ad was subject to VOD Advice and was approved because they considered that the appearance of the models was not problematic, and they did not look underweight.


Not upheld

The complainant’s concerns related to two of the four female models who featured in the ad.

The ad contained scenes in which the models’ heads and upper torsos were seen, and in these we acknowledged that both models appeared to be slim. In two of these scenes the first model was shown wearing a spaghetti strap dress which showed clearly defined collarbones and angular shoulders. However, we considered these scenes were very brief and that neither the ad’s lighting nor the model’s pose acted to accentuate these features. We considered that in those other scenes featuring the models, where only their faces were visible, both appeared healthy. We concluded that, although the models were slim, they did not appear to be unhealthily thin, and therefore the ad was not irresponsible.

We investigated the ad under CAP Code (Edition 12) rule  1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society.  (Social responsibility), but did not find it in breach.


No further action necessary.

CAP Code (Edition 12)


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