Advertisment
Social Media:
Advertising on the advertisers’ social media accounts for the product ‘Glazevale’ included the following statements:
“Glaze Vale. Skincare Essentials.
100% Grass Fed Tallow
Irish Company”
The post also included the following:
“Handcrafted with grass-fed tallow, raw honey & zero nasties …”
The post included various hashtags, including:
“#IrishMade”
Website:
The product listing on the advertisers’ website stated:
“Tallow Honey Balm
100% Grass-Fed Tallow”
The ingredients list on the product page stated:
“Grass-Fed Beef Tallow
Raw Honey
Olive Oil
Essential Oils”
In the FAQ section at the bottom of the webpage it stated:
“What is Glazevale Tallow Honey Balm made from?
Our balm is handcrafted from 100% grass-fed beef tallow, organic cold-pressed oils, raw honey, and essential oils – nothing synthetic, ever. Every ingredient is chosen for deep nourishment and natural skin repair.”
Complaint
Two complaints were received regarding the advertising raising the following issues.
Issue 1:
The complainants considered the social media advertising misleading as it claimed that the product was Irish made as, after placing an order, they noted that the product was shipped from China.
Issue 2:
A complainant considered the ingredients listed in the advertising was misleading as, while the product name on the label was “Woodsleep Tallow Honey Balm”, the list of product ingredients on the label did not include any of those listed in the advertising.
Response
Issue 1:
The advertisers stated that the reference to the product being “Irish-made” was included in error during the early stages of setting up their product page. They said it had only been online for a short period and was removed as soon as they realised it could be misleading. They confirmed that the product was not manufactured in Ireland and that there was now no wording on their website that suggested it was. They apologised sincerely for the mistake and for any confusion caused.
Issue 2:
The advertisers said that their supplier had made a mistake and had shipped lotions instead of the tallow balm to customers. They said that as a new business owner with very little experience, they did not realise the supplier error but once they were informed by customers, they took action straight away and refunded or sent replacement orders. They said that because of this mistake, the ingredients listed at the time were not accurate, however, since then they had changed supplier and corrected the formula to make sure that all ingredient information and advertising was accurate and up to date.
They also said that their product did contain tallow and honey, however, it also contained additional ingredients that formed part of the full formulation from their manufacturer.
They said that the complete and correct ingredient list was displayed on their website so customers could see all ingredients used in the product, including tallow and honey alongside the other components of the formula. They provided a snip from their current website showing the ingredients list.
Further Information:
The Executive noted that the image provided by the advertisers was taken from an updated version of the Tallow Balm website.
Conclusion
The Complaints Council considered the detail of the complaints and the advertisers’ response.
Issue 1 – Upheld:
The Council noted that the claim in the advertising was that the product was made in Ireland and that the complainants objected on the grounds that the product was not made in Ireland. The Council considered the Code requirements that advertising should not mislead, or be likely to mislead, by inaccuracy, ambiguity, exaggeration, omission or otherwise (S. 4.1); should not exploit the credulity, inexperience or lack of knowledge of consumers (S. 4.4) and that claims made in a marketing communication should be capable of substantiation and such substantiation be provided to the ASA (S. 4.9 and 4.10).
The Council noted the acknowledgement that the product was not made in Ireland and that the claim had been made in error. They considered that the impression created by the advertising was that the product was made in Ireland and as the product was not made in Ireland, the advertising was misleading and was therefore in breach of Sections 4.1, 4.4, 4.9 and 4.10 of the Code.
Issue 2 – Upheld:
The Council noted the claim in the advertising that the product was made from “100% Grass-Fed Tallow” and that it contained ingredients such as honey, olive oil and essential oils. The Council considered that the reasonable impression created by the advertisement was the product only contained the ingredients listed in the advertising.
Given that the products received by the complainant did not contain any of the advertised ingredients and that the listed ingredients currently on the website contained additional ingredients, the Council considered that the advertising at the time of the complaints was misleading and therefore in breach of Sections 4.1, 4.4, 4.9 and 4.10 of the Code.”
Action Required:
The advertising should not re-appear in its current form. The Council reminded advertises to ensure that they held evidence to hand for all claims made in their advertising.
