COSMETICS BUSINESS LIVE
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Howclaims can differentiate your brand (and how to
do it credibly) Speaker Stewart Long
I
n terms of claims, when you’re thinking about ‘who is my audience?’, you’ve got two. You’ve got the consumer, who wants to be confident that the product they’re buying from you is safe and delivers the promised benefits. And the regulatory authorities, who want to know the same. But I also want you to think ‘am I saying something interesting?’ – am I differentiating myself from the brands on the shelf next to me? Does it express my brand identity? And also does the consumer get it? People say to me that everything has been done. And it has in a way, but there’s always an opportunity for the right products with the right delivery. That’s where your communication on claims is really powerful.
THE RULES
The regulators (in the UK) are the ASA (the Advertising Standards Authority); Trading Standards, which is less active; and Clearcast, which pre-clears all advertising for TV. And the CAP Code of Practice tells you what you need to do for broadcast and non-broadcast advertising rules, which includes websites and social media. Ultimately, it’s got to be legal, it’s got to be decent, it’s got to be honest – this is where having the evidence comes in – and truthful. And you have to have adequate and appropriate evidence to support claims.
The EU Cosmetics Regulation also states that proof of the effect claimed must have evidence to support it. You can’t just say things and you can’t imply the products have characteristics or functions that they don’t.
One of the big areas we see problems with is straying into medical claims, eg, treats eczema, treats acne – you can’t say these things.
cosmeticsbusiness.com
Stewart Long said brands making claims should ask themselves ‘am I saying something interesting?’
There’s a Common Criteria for claims, which tells you what the levels of evidence should be, what is best practice and what the advertising regulators will accept.
WHAT IS A CLAIM?
So what constitutes a cosmetic claim? The following are all claims: the product and ingredient action or benefits; what it contains, or doesn’t contain; how you use it; comparing it to another product; testimonials, which have to be supported by representative amounts of evidence for the claim; who should use it; how it has been tested, trademark patents, etc; endorsements, whether it’s an Instagram influencer, a doctor, etc; and who recommends it. Even a picture of the pack and a picture of somebody using it is a claim.
If you get it wrong, you can be challenged. If you get it right, you can get your message across really powerfully.
A single word can change a claim. It can invalidate all the testing you’ve done. The way we like to work, when people come to talk to us about testing, is to say ‘what are you going to say on pack to advertise? What are the exact words?’ Do not get the data and then decide what you’re going to say about it.
SUPPORTING CLAIMS That’s the background to claims. So how do you then go about supporting them? The things that you need to consider are, how many people do you need to make that claim statistically?
We run lots of user studies for companies and you need a minimum of 50 people on a study. The ASA requires you to have at least 50 to be representative. Also, statistically, can it be supported to say that something is the case? You’ve likewise got to have the right demographic and physiological conditions. And is it just one test, or do you need a whole body of evidence? If you just want to say ‘all day moisturisation’, we can run a moisturisation test. If you want to say ‘people felt their skin was moisturised all day’, you will probably want to run a user study as well to get the consumer experience to support that.
And if you’re making a big, new bold claim – like microbiome – you’re gonna need a stack of data, because it’s new. You’d need a body of evidence. User trialling is sometimes looked at as a poor person’s version of claims testing. But actually, it is really powerful, because it is one of the ways that you get the consumer experience of the product. But you’ve got to get it right. The questions have got to be asked in the appropriate way, so that you’re not guiding people.
Of course, if you want quantitative changes, then you’ve got to do a clinical study. So, for instance, if you want to say ‘reduces wrinkles by 20% in two weeks’, you have to measure that, because the consumer cannot tell you that.
The other thing about clinical trials is you can measure multiple endpoints, eg, redness, skin radiance, wrinkles, pigmentation, etc. And you can get lovely images like 3D scans of lip volume or wrinkle depth.
A really powerful way of supporting advertising claims is through expert clinical grading. Because, if you can describe a visible change, that puts you very firmly within the EU Cosmetics Regulation, which defines a cosmetic as ‘changing the appearance temporarily of skin’. It keeps you out of medical claims. But it’s also really positive for the consumer.
Linked to this is something we do quite a lot of – because if you can see it, then it is a really good thing to communicate – and that is the blind assessment of images.
There is a lot you can do. But ensure you have a vision of where your brand is going and what you want to say about it. Also know how you want to share this, and how you’re going to integrate the technical with the marketing
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