A TV ad, for Dove soap, showed test paper being applied to four different bars of soap. It included a voice-over that stated, "This test paper is designed to amplify just how different soaps can be. Now watch what soap does to it." On-screen text shown while the test paper was on bars labelled "Face soap", "Baby soap" and "Family soap" stated "Time lapse 2 minutes with repeated water applications". The paper shown with each of those bars disintegrated and the voice-over continued, "When soap damages this paper, it indicates how drying it can be on your skin. Dove is different. With one-quarter moisturising cream, Dove doesn't dry your skin like soap can." The on-screen text did not appear when the bar of Dove was shown and the test paper on it remained intact.
Ten viewers challenged whether the ad was misleading, because they believed the Dove soap was not subject to the same test conditions as the other bars and that the comparison was therefore unfair.
Unilever UK Ltd (Unilever) said the ad was made to show the difference between a Dove soap bar and a variety of other soap bars. The test, which used a thin film of zein protein, an industry standard commonly used in vitro for screening the relative harshness of surfactant systems, was shown to demonstrate that Dove was milder and less drying. They said the soap bars were each subject to exactly the same test conditions.
Unilever said the test shown in the ad was from a real-life demonstration and used time lapse to depict the results. They said the on-screen text "Time lapse 2 minutes with repeated water applications" appeared when the first soap bar was shown and was held for a duration in line with Broadcast Committee of Advertising Practice guidance. They said it was purely coincidental that the text faded out before the test on the Dove bar was shown. They submitted a video of an initial test demonstration and explained that a 2012 zein assay study had been used as a reference for the ad, although further tests had been carried out specifically for its creation. Unilever also submitted photos taken during the testing. They believed the ad was not misleading, but said they would be prepared to extend the duration for which the on-screen text appeared if the ad was used again in future.
Clearcast said the test was carried out under the exact same conditions for all of the soap bars. They said they, and their consultant, were involved in approving the script for several months and were satisfied with the final ad.
The ASA noted the photos and video submitted by Unilever. They depicted various bars of soap, which we understood to include most of the soap bars shown in the ad. The video showed water being applied to five soap bars at intervals while a timer ran for two minutes. The photos showed soap bars at the beginning of the test and at the time at which the paper doll had disintegrated. We considered the evidence demonstrated that a range of soap bars had been subject to the same test conditions and that the ad fairly represented that. While we acknowledged the time at which the on-screen text disappeared seemed to have led some viewers to believe that the Dove bar was subject to different test conditions to the other bars, we noted that was not the case. We therefore concluded that the depiction of the test conditions was not misleading.
We investigated the ad under BCAP Code rules 3.1 3.1 Advertisements must not materially mislead or be likely to do so. (Misleading advertising), 3.9 3.9 Broadcasters must hold documentary evidence to prove claims that the audience is likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation. (Substantiation), 3.10 3.10 Advertisements must state significant limitations and qualifications. Qualifications may clarify but must not contradict the claims that they qualify. (Qualification) and 3.38 3.38 Advertisements that include comparisons with unidentifiable competitors must not mislead, or be likely to mislead, consumers. The elements of the comparison must not be selected to give the advertiser an unrepresentative advantage. (Other comparisons) but did not find it in breach.
No further action necessary.