Ad description
A paid-for Facebook ad for Rimmel London, seen on 9 September 2023, included the caption “Get ready to slay this back to school season [books emoji] [stars emoji] Get 25% off Multi-Tasker Concealer and other Rimmel faves with code B2S25 only at lookfantastic.com”.
The post included a video of influencer Lana Jenkins applying makeup and a product shot of Rimmel’s “THE MULTI-TASKER CONCEALER”. The video included large on-screen text that stated “CONTOURED QUEEN”.
Underneath the video, text stated “LOOKFANTASTIC.COM 25% off Rimmel back to school” and included a button labelled “Shop Now”.
Issue
Two complainants, who believed the claim “Get ready to slay this back to school season” played on young girls’ insecurities by implying they were only ready for a new school year if they wore make-up, challenged whether the ad was irresponsible.
Response
Coty UK Ltd t/a Rimmel London (Rimmel) said that the campaign in no way communicated a need to wear make-up, but rather focused on trending make-up looks which the viewer could re-create should they wish.
The ad was part of their “Back to School” campaign and contained video content created by their paid ambassador, Lana Jenkins who was 25. The ad was intended to refer more generally to the period of time starting in September for anyone going back to work including, for example, university students, mums and teachers. The ad targeted women aged 18-35 years in the UK interested in cosmetics, beauty, fashion and make-up. They provided targeting data to demonstrate that. Additionally their own internal guidelines specified that they did not market to children.
The term “slay” was commonly used amongst their target audience and they believed it to be a positive term which meant to do something spectacularly well. The claim “Get ready to slay this back-to-school season” was intended to motivate and build confidence, rather than prey on young girls’ insecurities. They acknowledged that some people viewed make-up in a negative light, but they highlighted that make-up could also be liberating by allowing people to express themselves and look and feel amazing.
They confirmed that the “Back to School” marketing campaign had ended and that they had no current intentions to use the ad in future marketing activities.
Assessment
Upheld
The CAP Code required marketing communications be prepared with a sense of responsibility to consumers and to society.
We acknowledged Rimmel’s comment that “back to school season” could refer to university students, mums and teachers, which they said were their intended target, and not just school and college aged children and young people. However, the ASA considered that the words “back to school season” in this ad, in conjunction with the vibrant pink colour scheme, the books and star emojis and the fluffy pink pen held by Ms Jenkins in the video, would primarily be understood by viewers as referring to the time of the year when students return to senior school or sixth form college after the summer break and would be perceived as speaking to that age group, and would have appeal to them.
Although make-up was not an age-restricted product, we noted that Rimmel had used age- and interest-based targeting tools to target the ad away from under-18s. However, those targeting tools would not have the effect of avoiding all under-18s from seeing the ad and we therefore considered whether the content of the ad was irresponsible for that audience.
We considered that the use of the word “slay” in the claim "Get ready to slay this back to school season" implied that girls or young women were more likely to succeed or do well when they went back to school if they wore make-up, in this case a concealing and contouring product. We considered the ad had the effect of playing on young girls’ insecurities about their appearance and therefore concluded it was irresponsible.
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 Coty UK Ltd t/a Rimmel London that they should not play on young girls’ insecurities by implying that it was necessary to wear make-up to school to succeed.
