Ad description
Three paid-for Facebook ads for ZING Toothpaste.
a. The first ad, seen on 2 November 2025, featured an image of teeth and a tube of mint toothpaste. Five white stars in green squares with a cut-in below the right-hand point featured at the bottom of the image, with the text, “Loved by 67,000+ UK customers”.
b. The second ad, seen on 3 November 2025, featured an image of a tube of lemon toothpaste. A white rectangle at the bottom of the ad featured the text, “Excellent”, “Based on 13,183 reviews”, and five white stars in green squares with a cut-in below the right-hand point.
c. The third ad, seen on 5 November 2025, featured an image of a tube of peach toothpaste. A white rectangle at the bottom of the ad featured the text, “Excellent”, “Based on 13,183 reviews”, and five white stars in green squares with a cut-in below the right-hand point.
Issue
The complainant, who understood that ZING Toothpaste did not have the number of reviews in the ads, or a five-star rating on Trustpilot, challenged whether the ad was misleading.
Response
ZING Oral Care Ltd t/a ZING Toothpaste said that when the ads were created the Trustpilot rating and number of reviews were accurate. They explained that they later moved to a new review software provider which caused their original Trustpilot reviews and five-star rating to disappear. They said they had not realised the switch would reset their Trustpilot profile.
They said that since the change they had received over 1,000 reviews, 85% of which were five stars. They believed the rating on the ad accurately reflected customer feedback. They also said Trustpilot had given them permission to continue using star ratings in their ads.
ZING Toothpaste said that they will update their ads to show the star ratings from their new review software provider.
Assessment
Upheld
The ads featured five-star ratings, presented as five white stars inside green squares. The ASA considered consumers would understand that the colours and the star shape used were identical to Trustpilot’s Star Rating. The text, “Excellent” in ads (b) and (c), which we understood Trustpilot displayed for companies with a Star Rating over 4.3, reinforced that interpretation. We further considered that consumers would understand the five stars alongside the claim, “Excellent Based on 13,183 reviews” in ads (b) and (c) to mean that ZING Toothpaste had an average rating of five stars on the Trustpilot website, and that rating was based on over 13,000 genuine customer reviews. We also considered that consumers would understand the five stars alongside the claim, “Loved by 67,000+ UK customers” in ad (a) to mean that ZING Toothpaste had an average rating of five stars on the Trustpilot website, based on over 67,000 reviews from UK customers.
We understood that on 18 September 2025, ZING Toothpaste had 67 reviews on their Trustpilot page, with a Star Rating of 4.2 and “Great”. Further, on 13 November 2025, ZING Toothpaste had 82 reviews on their Trustpilot page, with a Star Rating of 4.2, and “Great”. We considered that these ratings did not substantiate the ratings used in the ads. In addition, ZING Toothpaste provided no further data to prove that the ratings used in the ad were genuine.
Because the ratings appeared to be a five-star Trustpilot rating for the company based on 13,183 reviews in ads (b) and (c), and over 67,000 in ad (a), and we had not seen evidence that ZING Toothpaste had a rating of five stars or those numbers of reviews on Trustpilot, we concluded that the ad was misleading.
The ads breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation).
Action
The ads must not appear again in the form complained of. We told ZING Oral Care Ltd t/a ZING Toothpaste not to claim or imply that they had a five-star Trustpilot rating if they did not hold evidence to demonstrate that this was the case.
