Note: This advice is given by the CAP Executive about non-broadcast advertising. It does not constitute legal advice. It does not bind CAP, CAP advisory panels or the Advertising Standards Authority.
What is intravenous nutritional therapy?
Intravenous nutritional therapy (IVNT) or ‘IV drips’ are sometimes offered by wellness and/or aesthetic clinics. They typically consist of a fluid bag of saline, containing vitamins and minerals and other substances which are administered directly into the blood stream through the vein.
Some clinic websites which reference the available therapies make claims about the benefits of the individual drips, with different drips and ingredients purporting to have different benefits. The ASA has considered that in many cases, the average person to whom these clinic ads are addressed would be generally healthy, but are likely to be interested in products which might support or enhance specific aspects of their health and wellbeing.
Whilst health and nutrition claims about nutritional supplements (taken orally as a food) are subject to rules which specifically restrict their use (as detailed in Section 15 of the CAP Code), the same restrictions do not apply to IVNT. However, the ASA and CAP are likely to expect marketers to hold robust documentary evidence to support any claims about the benefits of individual products.
What kind of evidence is necessary for claims of a beneficial effect?
Based on published rulings for INVT products, there are a number of factors that the ASA are likely to take into consideration when reviewing evidence for advertising claims about the benefits of IVNTs.
In most cases, especially where IVNTs are given as a one-off treatment, the ASA considered that consumers are likely to expect that an IV drip to be instantaneous, and therefore more effective, or a superior way, of delivering essential nutrients to normally healthy people than other methods (such as through diet or regular oral supplementation). Consumers would therefore also expect the drips to provide superior health benefits more quickly than the same nutrients administered through such other methods. As such, the ASA is likely to expect the evidence to reflect this. Other expectations of evidence are set out below:
Whilst the ASA accepts it is feasible for clinical evidence on the benefits of oral supplementation to be cross applied to IVNT’s, marketers will need to hold evidence to show a correlation between a specific dose (including quantity, frequency and duration) and the stated health benefit. Evidence will also show the IVNT in question contains the same or greater dose as the oral supplementation on which the study was based.
It is unlikely to be acceptable to rely on studies which examine regular supplementation and extrapolate it to a one-off IVNT infusion.
It is unlikely to be acceptable to rely on evidence which considers the treatment of vitamin deficiency.
The ASA is likely to expect marketers to be able to demonstrate the IVNT contains no additional ingredients which could impact the effectiveness of the nutrients and that the lack of involvement of the gut microbiome (which is normally involved in oral supplementation) does not prevent the nutrient from having the claimed effect.
The ASA is likely to expect all evidence (either RCTs or observational studies) to be methodologically robust with clinically significant outcomes that are directly relevant to the health benefits claimed in the ad.
This CAP Guidance explains the types and levels of evidence the ASA would expect marketers to hold.
What kind of claims are likely to be problematic?
The ASA has yet to see convincing evidence to support the claimed benefits of specific IVNT’s.
Any claim of a specific benefit from an IVNT is likely to be problematic unless the supporting evidence is robust (and in line with the expectations stated above). This may include general references to things like “mood”,” energy”, and “immunity”, as well as more specific references to things like “Reboot your immune system”, “fast recovery”, “cleanses vital organs”, “burn off stubborn fat” and “calm your mind”.
Claims about the aesthetic benefits of a IVNT should also be supported by robust documentary evidence, including claims that make reference to the appearance of the skin.
Even if claims are supported by robust documentary evidence, marketers may need to make clear in the ads the duration of any beneficial effect to in order avoid the impression that a one-off treatment may have a longer-term benefit than the evidence shows.
See ASA rulings: Get a Drip, GMG Pharmacy and Reviv UK, 20 December 2023.
What about claims in IVNT product names?
Marketers should be aware that the name of a product or therapy could imply a claim of a beneficial effect. Even if the description of a therapy doesn’t otherwise make claims about the benefits of a specific drip, the name itself could make implied treatment claims and this would likely trigger the need to hold robust documentary evidence to support that implied claim.
What about medicinal claims?
Claims to treat, alleviate, prevent or cure a medical condition (in body or in mind) are likely to be considered medical claims. Such claims are unlikely to be acceptable unless the IVNT has been licenced as a medicine and the treatment claims in the ad comply with the Summary of Product Characteristics (SPC) that accompany that licence (rules 12.1 and 12.11). Marketers can contact the Medicines and Healthcare products Regulatory Agency (MHRA) for more information on medicines and medicinal claims for IVNT products.
In 2020, during the COVID-19 pandemic, the ASA published rulings about advertising claims that IV drips could be used to prevent or treat COVID-19. The MHRA had advised the ASA that any mention of coronavirus/COVID-19 in the promotion of an IV drip product would bring the product under medicines regulations, as would any claim that implied treatment of, or protection from, the virus. Because the ads for the IV drips made medicinal claims for products which were not licensed as medicines to treat or prevent that condition, the ASA ruled that the ads breached the CAP Code (rules 12.1 and 12.11). (Cosmetic Medical Advice UK, The Private Harley Street Clinic and Reviv UK Ltd, 22 April 2020).