Background
This Ruling forms part of a wider piece of work on ads for liquid BBLs (Brazilian Butt Lifts), identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A paid-for Facebook ad for Bomb Doll Aesthetics, a cosmetic treatment provider, seen in November 2024. The ad featured a video of text that stated, “BLACK FRIDAY Save up to 70%! Valid until 30th November. YOU DON’T WANT TO MISS THESE DEALS” followed by a list of treatments offered, including Liquid BBLs and the respective price. Text in the caption stated, “Black Friday Bomb Deals Don’t miss out on these big savings - up to 70% off on our signature treatments!”
Issue
The ASA challenged whether the ad was irresponsible because:
- the time-limited “Black Friday” offer pressured consumers into booking a cosmetic procedure; and
- the claim “you don’t want to miss these deals” trivialised the risks of cosmetic procedures.
Response
Bomb Doll Aesthetics Ltd did not respond to the ASA’s enquiries.
Assessment
The ASA was concerned by Bomb Doll Aesthetics’ lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay). We reminded them of their responsibility to provide a response to our enquiries and told them to do so in future.
1. Upheld
The CAP Code required marketing communications to be prepared with a sense of responsibility to consumers and to society. The ad was a Black Friday promotion for “liquid BBLs” (Brazilian Butt Lift) and other cosmetic procedures. We understood that a liquid BBL involved the injection of dermal filler into the buttocks to enhance their volume and shape. We understood from guidance from the Joint Council for Cosmetic Procedures that liquid BBLs were considered to be surgical procedures, which carried a level of risk. We considered that, although it would not have necessarily been irresponsible to offer promotions for such procedures, marketers would need to take particular care when administering them. Undertaking cosmetic surgery should have been portrayed as a decision that required time and thought from consumers before proceeding, because of the risks involved.
We understood that “Black Friday” referred to a specific day in the year when many businesses offered promotions. Because promotions often only lasted for several days or weeks around that day, we considered consumers would have understood references to “Black Friday” to mean that the opportunity to take up the offer was time limited. We considered the combination of the phrases “Black Friday Bomb Deals”, “up to 70% off”, “Valid until 30th November” and “YOU DON’T WANT TO MISS THESE DEALS” created undue emphasis on the promotion’s limited timeframe. We considered that was likely to have led consumers to fear they would have missed out on the offer if they had not booked quickly.
In that context, we considered that consumers could have been rushed into making a decision to have cosmetic surgery without taking sufficient time to consider the consequences. Because the ad created a sense of undue urgency to book a cosmetic procedure quickly, we considered that it had not been prepared in a socially responsible manner and therefore breached the Code.
On that point, the ad breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
2. Upheld
CAP Guidance on cosmetic interventions stated that marketers should not trivialise such procedures or suggest they could be undertaken lightly, because it was likely that all such interventions would carry some level of risk to the patient, such as infections. It was therefore important that marketers presented such procedures responsibly in their advertising.
The ad referenced a number of cosmetic procedures, including liquid BBLs and fillers alongside the claims “YOU DON’T WANT TO MISS THESE DEALS” and “Don’t miss out on these big savings”. The tone of the ad was urgent and focused on the opportunity to book a cosmetic procedure during a Black Friday sale. The ad portrayed the Black Friday offer as something which needed to be acted on quickly in order to capitalise on a lower price or “deal” which may not be available again due to the limited timeframe. The ad failed to highlight that there were risks involved in any cosmetic procedure, and it created the impression that a low price or promotional offer was the most important factor when making the decision to book a cosmetic procedure. In that context, the ad portrayed the decision to have cosmetic surgery as one that was not serious and could be taken without proper consideration and quickly to capitalise on a promotional offer. Because the ad detracted from the seriousness of the decision to undertake a cosmetic intervention, we concluded that it trivialised the risks of the surgery and was socially irresponsible.
On that point, the ad breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
Action
The ad must not appear again in the form complained of. We told Bomb Doll Aesthetics Ltd to ensure that future ads did not pressure consumers into booking, or trivialise the risk of, cosmetic procedures. We referred the matter to CAP’s Compliance team.
