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Gold Collagen Claims Again Fail To Shine Under UK Scrutiny

This article was originally published in The Rose Sheet

Executive Summary

The UK Advertising Standards Authority says Minerva Research Labs did not support claims of "younger-looking skin," “healthier hair,” and “stronger nails” for its Pure Gold Collagen, Active Gold Collagen and Gold Collagen Forte supplements.

The maker of Gold Collagen beverage supplements for the second time in 15 months fails UK advertising regulators' scrutiny of its skin care claims.

The UK Advertising Standards Authority on Dec. 7 reported that Minerva Research Labs Ltd. did not support claims of "younger looking skin," “healthier hair,” and “stronger nails” for its Pure, Active and Forte versions of the supplements containing ingredients including vitamin C, zinc and biotin.

ASA said the London business, operating in the US as Minerva Research Labs Inc., violated UK regulations prohibiting misleading advertising and using unauthorized health claims and requiring substantiation for claims in a print advertisement challenged by one complainant in January.

In September 2015, ASA said the firm presented inadequate evidence to substantiate implied claims about skin and collagen improvements. Eight complainants challenged whether a TV ad misleadingly implied that Minerva's product could directly affect the quality and collagen properties of users' skin. (Also see "Implied Claims For Gold Collagen Liquid Supplement Hard To Swallow – ASA" - HBW Insight, 17 Sep, 2015.)

The challenged print ad stated "more and more women are waking up to Gold Collagen" and included footnote information about clinical trials with results published in medical journals and about the product formulation's benefits.

According to ASA's report, Minerva contended the statement "younger-looking skin" was a cosmetic claim and that they had gathered significant consumer opinion on the efficacy of their products. It also provided reports of published clinical trials and an internal consumer perception report.

Additionally, Minerva said "younger looking" was "clearly an impressionistic and subjective claim," the ad made no indication of how much younger users' skin would look and that "many, if not all, consumers" would consider the statement to be puffery' and would not be misled.

ASA said the claim "was likely to be understood" as being about the cosmetic effect of the products, but it is "an objective statement that users would see a difference in the appearance of their skin" and is not puffery.

Further, because the "effects of oral consumption of collagen on the body were not well-established," the claim required "a high standard of evidence … both with regard to objective changes in skin quality and consumers’ perceptions of their skin age."

Minerva failed to deliver the support. ASA questioned the methodology and design of some of the trials the firm submitted, noted that results of other trials did not address the claim nor show improvements in subjects’ perception of their skin and that results of a single in vivo trial were not strong enough to overcome those concerns.

ASA agreed with Minerva that “healthier hair” was a compliant general health claim and was accompanied by the three specific claims in the ad footnote, but noted the footnote was in small type and considerably separated from the claim.

The agency said "this combination of separation and lack of prominence meant that the accompanying authorized claims were likely to be overlooked by consumers viewing the ad, and that they should have been more prominently presented within the ad and placed next to or following the initial statement."

With the claim “stronger nails,” Minerva strayed too far from the approved claim “maintenance of normal nails” for zinc and biotin, ASA said. Similarly, the claim is about the advertised product, "not with regard to zinc and biotin specifically," and no claim is approved specifically for the Gold Collagen formulation.

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