New York, NY – June 27, 2024 – In a challenge brought by SC Johnson & Son Inc. (SCJ), BBB National Programs’ National Advertising Division determined that certain claims made by Procter & Gamble Company (P&G) for its Native brand of personal care products are supported, including:
- P&Gs use of “simple” in its tagline “Clean. Simple. Effective.”
- Monadic “safe” claims such as “safe & simple products made without harsh ingredients.”
However, the National Advertising Division (NAD) recommended that P&G:
- Modify or discontinue use of “simple ingredients” when describing Native product ingredients for its deodorants, body washes, body lotion, conditioners, and shampoos.
- Discontinue its “Born in the USA” claim.
SCJ, maker of the Method brand of products, challenged claims found on product packaging, advertising, and Amazon listings for P&G’s Native brand of personal care products.
“Simple” Claims
The National Advertising Division (NAD) determined that one message reasonably conveyed by “simple” in Native’s tagline, “Clean. Simple. Effective,” is that Native products contain few or minimal ingredients. NAD found that P&G substantiated the claim and determined use of the tagline is substantiated in the context of Native’s product packaging and website.
SCJ also challenged Native’s use of “simple” in reference to individual ingredients in Native Products instead of the product formulations as a whole: “simple ingredients,” “simple & effective ingredients,” or “simple ingredients you can understand at a glance.” NAD determined the description of Native ingredients as “simple” is not supported for its deodorants, body washes, body lotion, conditioners, and shampoos and recommended that P&G discontinue or modify its use of the “simple ingredients” claims when describing these products.
Safe Claims
The National Advertising Division (NAD) determined that one message reasonably conveyed by a monadic unqualified “safe” claim is that the product is safe when used as directed. NAD noted that while advertisers are responsible for all messages reasonably conveyed by their advertising, they are not obligated to support unreasonable interpretations of their claims, such as the message that the product is safe for all possible uses, even unintended ones, or that the product is safe for consumers to misuse contrary to product directions.
NAD found P&G’s monadic “safe” claims, such as “safe & simple products made without harsh ingredients” and “safe, synthetic, sustainable fragrances (free of phthalates),” used on Native products to be supported.
“Born in the USA” Claim
The National Advertising Division (NAD) determined that one message reasonably conveyed by P&G’s “Born in the USA” claim is that Native products are made in the USA. NAD noted that the Federal Trade Commission standard for “Made in USA” claims require that “all or virtually all” of the cost of the goods sold be attributable to domestic sources. Since P&G did not provide any evidence that its products are made in the USA, NAD recommended that the claim be discontinued.
During the proceeding, P&G permanently discontinued certain claims. Therefore, NAD did not review these claims on their merits and will treat the claims, for compliance purposes, as though NAD recommended they be discontinued.
In its advertiser statement, though P&G “respectfully disagrees” with certain of NAD’s determinations, it agreed to comply with NAD’s recommendations.
All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. This press release shall not be used for advertising or promotional purposes.
About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.
About the National Advertising Division: The National Advertising Division of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. The National Advertising Division reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.
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