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 the 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 complainant challenged whether the implication that other soaps dried the skin was misleading and could be substantiated.
Unilever UK Ltd said that soaps in the UK were based on generic formulations with some intrinsic similarities. They said soap reacted with calcium in water, which then formed deposits on the skin. As soap was alkaline, it altered the surface of the skin and its ability to retain moisture. They said that routine cleansing with soap-based products often left the skin feeling taut and dry, which was the result of damage to the outer protective layer of the skin (the stratum corneum). They said that this outer layer was responsible for regulating the water content of the underlying layers of the skin. Furthermore, they said that damage to the outer layer of the skin resulted in increased water loss that led to lower skin hydration levels.
Unilever said that during the ad, a thin film of zein protein was used on the surface of each soap. This protein was commonly used as an industry standard for in vitro testing for the relative harshness of surfactants by measuring the amount of protein that was removed which reflected the overall harshness of a product's surfactant. They said that the harsher the surfactant in a cleansing product, the more the skin was unable to retain moisture, which led to dryness. They provided a graph which they said showed that several soaps dissolved a significantly high percentage of zein protein. This meant that these soap-based products had a harsher surfactant system, which caused skin to dry.
Clearcast said they had considered the script and had been careful not to overstate the effects of the soaps on the skin. They said their consultant was happy that the zein protein test was an industry standard method that indicated surfactant harshness in a soap product and also visualised the removal of protein from skin over time, which consumers would experience as leaving the skin dry. They said that the claim related to the general drying effect on the skin from some soaps, which were not specified, not that all soaps dried skin. They provided comments from their consultant who advised on the development of the ad.
The ASA understood that cleansing products caused some degree of drying to the skin which was affected by composition such as the amount and type of surfactant used, and the pH, which would affect the skin surface, resulting in varying degrees of dryness. Furthermore, a higher surfactant content and a more alkaline pH, were likely to cause an increased drying effect on normal skin. We noted that the test was used to demonstrate the level of surfactant in a product which correlated with the drying effect of soap on the skin.
We understood that the complainant's concern related to whether soap in general, rather than the Dove soap, dried the skin. We considered that the ad focused on generic soap products and we therefore considered that consumers would understand that the ad made a general claim about soaps and their drying effect on skin. Furthermore, we understood that skin drying was generally accepted as one of the negative consequences of soap use and that some products would result in varying degrees of dryness, while the effect would be less so for other products. Because the ad made a general claim about soaps and their commonly accepted drying effect, we concluded it was not misleading.
We investigated the ad under BCAP Code rules
Advertisements must not materially mislead or be likely to do so.
Advertisements must not mislead consumers by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that consumers need in context to make informed decisions about whether or how to buy a product or service. Whether the omission or presentation of material information is likely to mislead consumers depends on the context, the medium and, if the medium of the advertisement is constrained by time or space, the measures that the advertiser takes to make that information available to consumers by other means. (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), 3.12 3.12 Advertisements must not mislead by exaggerating the capability or performance of a product or service. (Exaggeration) 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.