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:
Three issues were investigated, all of which were Upheld.
Ad description
A paid-for Facebook ad for CCskinlondondubai, a cosmetic treatment provider, seen in November 2024. The ad featured an image of a gift-wrapped present and text that stated “SALE BLACK FRIDAY BBL. HIP DIP. BREAST”, accompanied by a list of procedures and the respective price. The word “sale” was superimposed in the background several times. Text in the caption stated, “Get the curves and contours you’ve always wanted with our safe and effective body filler treatments. Feel confident every step of the way! Safe, proven, and beautifully natural results. Expertly qualified team”.
Issue
The ASA challenged whether the ad was irresponsible because:
- the time-limited “Black Friday” offer pressured consumers into booking a cosmetic procedure;
- it exploited women’s insecurities around body image and linked confidence to cosmetic procedures; and
- the claims “safe and effective” and “safe, proven, and beautifully natural results” trivialised the risks of cosmetic procedures.
Response
CCskinlondondubai did not respond to the ASA’s enquiries.
Assessment
The ASA was concerned by CCskinlondondubai’s 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, marketers would need to take particular care when administering them. Having 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 the 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.
The ad stated “BLACK FRIDAY” and the word “SALE” was superimposed in the image several times, which we considered created undue emphasis on the promotions 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 play on consumers’ insecurities and must not suggest that happiness or wellbeing depends on conforming to a particular body shape or physical appearance.
The ad featured the claim “get the curves and contours you’ve always wanted” which we understood was targeted at women and implied they could change their body shape through cosmetic surgery. We understood that the actual end result would depend on a variety of factors and considered that the claim created unrealistic expectations of what could have been achieved from the surgery. We therefore considered the ad risked exploiting women’s insecurities around body image, particularly those with insecurities relating to their body shape. The ad also included the claim “feel confident every step of the way!”, which we considered implied that by changing their physical appearance, an individual could improve their confidence. Because the ad exploited women’s insecurities around body image and linked confidence to cosmetic procedures, we concluded that it was irresponsible.
On that point, the ad breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
3. Upheld
CAP Guidance on cosmetic interventions stated that marketers should not trivialise such procedures or irresponsibly describe them as “safe” or “easy”, 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 stated that different quantities of body filler could be injected into the bottom, breasts, or hips, alongside the claims “safe and effective” and “safe, proven, and beautifully natural results”. We considered that created the impression that deciding to have a procedure was not a serious decision and that it was straightforward and without risk, which was not the case. 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 about. We told CCskinlondondubai to ensure that future ads did not pressure consumers into booking a cosmetic procedure, trivialise the risks involved or exploit women’s insecurities surrounding body image. We referred the matter to CAP’s Compliance team.
