The National Advertising Division (NAD) of the Council of Better Business Bureaus has recommended that University Medical Pharmaceuticals Corp. discontinue the use advertising of claims for the company’s OTC product, WrinkleFree Eyes.
NAD examined print advertising for the product in accordance to NAD’s ongoing monitoring of national advertising. Claims that the NAD took issue with included: “Clinically proven to reduce wrinkle appearance up to 85% in only 20 minutes”; “Results as good as Botox only faster”; “Truly effective topical alternative to Botox"; "[t]his new technology works in only 20 minutes with results that last up to a week”; “Originally developed to deliver medicine into the skin without needles, this breakthrough transdermal process gently works faster, deeper and with less irritation than ever before possible with topical treatments”; and “You’ll see a dramatic smoothing effect around your eyes in only 20 short minutes that lasts up to a week.”
University Medical Pharmaceuticals Corp. responded to NAD's recommendation, noting that it had conducted internal studies with employees and friends but it reportedly did not provide the NAD with data or disclose the methodology. However, the company did provide the NAD with results of two studies: one including a test for the immediacy of results with the product used in conjunction with various concentrations of retinol, and another requiring individual subjects to use the product on one side of the face.
According to the NAD, neither study tested the product as it is marketed and both studies held numerous methodological flaws. Following its review, the NAD determined the evidence in the record did not support the advertiser’s performance and establishment claims, thus recommending use of the claims be discontinued. The NAD further noted that the evidence in the record did not include head-to-head testing between topically applied WrinkleFree Eyes and Botox, and that the evidence was insufficient to support the wrinkle-reduction claims and comparisons to Botox.
University Medical Pharmaceuticals Corp. released the following statement in response to the NAD's recommendation: “Notwithstanding University Medical's objections to the NAD's findings, University Medical will take them into consideration and will modify its advertising accordingly.”
The NAD's inquiry was conducted under NAD/CARU/NARB Procedures for the Voluntary Self-Regulation of National Advertising. Details of the initial inquiry, the NAD's decision, and the advertiser's response will be included in the next NAD/CARU Case Report.
This finding and controversy yet again underlines the necessity of putting real science behind the claims on product labels, especially to support the public's opinion of cosmetic science.