Ad description
A TV and Video on Demand (VOD) ad for Boots’ No7 Future Renew serum, seen in April 2024:
a. The TV ad began with a woman looking at a photograph from 10 years ago and she said, “Remember this? Can’t believe we didn’t always use sunscreen.” Small print stated, “Recommended with daily SPF usage”. Another version of the woman, with a second woman, came to life in a photograph and responded saying, “I know right, we were too busy having fun.” It then switched to a contemporary version of the first women in a photograph, saying, “Let’s not regret our sunny memories.” To which the second woman in a framed photo next to the first whispered, “Let’s do something about it.” The voice-over then said, “No 7 Future Renew serum.” The voice-over and on-screen text then said, “Clinically proven to reverse visible signs of sun damage. A world-first peptide technology.” Small print stated, “APPEARANCE OF FINE LINES & WRINKLES, UNEVEN SKIN TONE AND DULLNESS”. The final shot showed the range of No7 Future Renew products. The voice-over and on-screen text said, “Don’t regret just reverse.”
b. The VOD ad contained the same content as ad (a).
Issue
Eighteen complainants, who believed ads (a) and (b) condoned not using sunscreen by stating skin damage could be dealt with retrospectively with the product, objected that the ads were irresponsible and harmful, particularly due to the risks associated with skin cancer.
Response
The Boots Company plc t/a Boots said as a pharmacy-led retailer and a manufacturer of health and beauty products, including sun protection and skincare products, they took sun protection very seriously.
Their promotion of sunscreen and sun protection included partnerships with MacMillan Cancer Support, the Irish Cancer Society and the American Cancer Society. They also had various initiatives in store to train their staff to provide assistance and advice to consumers about sun protection.
Boots explained that the background to the ad was based on three pieces of consumer research. They showed many consumers regularly did not apply sunscreen or only did so when in the sun for extended periods or in full sunshine, and few understood that the main cause of the visible facial signs of ageing was the damaging effects of repeated exposure to the sun. Skin ageing was often seen by the women surveyed as an inevitability and even when they were made aware that 80% of visible skin damage was caused by the sun, they struggled to attribute it to the damage and not just the passing of time.
Boots said further, that 70% of annual exposure to the sun occurred outside of the traditional two-week summer holiday, including in the autumn and winter months. Based on that knowledge the ad depicted a series of outdoor memory scenarios, such as a picnic in the shade, a festival or a walk in the woods where both the settings and clothing shown indicated temperatures that were not especially hot. They were events where using sunscreen would not have been at the forefront of a person’s mind ten years ago.
Boots confirmed there was also intentionally no use of scenes such as the beach or pool, of prolonged lack of sun protection or of sun protection intentionally not being used. That was reinforced by the woman, in the first few seconds of the ad, saying, “I can’t believe we didn’t always use sunscreen” alongside superimposed text that stated “Recommended with daily SPF usage”. The ad therefore made clear that sunscreen was not worn consistently in the past and indicated that there was now a higher awareness of the need to wear it regularly. In addition, the superimposed text regarding “daily SPF usage” clarified that the advertised products should always be used with a daily SPF regime and that the use of No7 Future Renew serum, the featured product in the ad, did not mean that sun protection was not necessary.Boots said the ad also had additional on-screen text, “APPEARANCE OF FINE LINES & WRINKLES, UNEVEN SKIN TONE AND DULLNESS”, that qualified the spoken “Clinically proven to reverse visible signs of sun damage” claim. The ad therefore did not imply that all forms of damage caused by the sun could be addressed by using the No7 Future Renew serum and was prepared with a sense of responsibility to the audience and society.
Clearcast said the women in the ad were older, looking back at their younger days, and it was clear they regretted their decision to not wear sunscreen consistently. They noted that one of the women said, “I can’t believe we didn’t always wear suncream”, which made clear that the women historically did wear sun protection but not as regularly as guidance advised. They further highlighted the superimposed text in the ad that stated, “Recommended with daily SPF use” which meant the ad advised sun protection. They also raised that while the main product in the ad was the No7 Future Renew serum, the last frame of the ad showed the range of products and that included a day cream with SPF 40.
Clearcast explained the ad sold an anti-ageing cosmetic product and clearly defined who was being targeted. It was not aimed at young people and never suggested that it was a good idea not to wear sun protection. In contrast, the ad highlighted the specific cosmetic damage the sun does. The ad therefore, while promoting an anti-ageing product, was a positive example of why sun protection should be worn at all stages of life.Clearcast said that the ad only addressed the visible signs of sun damage and explained in the qualifying text what that meant. It would therefore have been clear to viewers, who they believed had a good knowledge of protecting their skin from the sun, that it was a cosmetic product and would not assist with serious conditions such as cancer, which went beyond the visible cosmetic signs highlighted in the ad. The ad therefore was not irresponsible or harmful.
Assessment
Upheld
The ASA acknowledged Boots’ argument that the examples of not using sunscreen were historic, and therefore not a reflection of the women’s current attitude, and that all scenes were of times when the sun was either low or obscured. However, the women in the ads made statements such as “too busy having fun” to have always used sunscreen and ”Let’s not regret our sunny memories” but “do something about it” using the product, which was stated to be “Clinically proven to reverse visible signs of sun damage”. On-screen text further said, “DON’T REGRET JUST REVERSE”.
We considered that the tone of the conversation between the women was light-hearted and flippant about the subject of sun damage and would be seen to suggest that not using suncream could be taken lightly. We considered that message was further reinforced by claims that the visible signs of damage resulting from previous exposure to the sun could be reversed by using the product. Although small on-screen text said, “Recommended with daily SPF usage”, it appeared at the beginning of the ad only for a brief period of time. For those reasons, we concluded the ads condoned exposure to the sun without sunscreen and therefore were irresponsible and harmful.
Ad (a) breached BCAP Code rules 1.2 (Compliance) and 4.4 (Harm and Offence), and ad (b) breached CAP Code (Edition 12) rules 1.3 (Compliance) and 4.5 (Harm and Offence).
Action
The ads must not appear in the form complained of. We told The Boots Company plc t/a Boots that ads should not condone or encourage the non-use of sunscreen.
