It’s In The Detail – Or Should I Say Small Print?

EURO COSMETICS Magazine • It’s In The Detail - Or Should I Say Small Print? • Theresa Callaghan • Theresa Callaghan
Skin Care Scientist and Cosmetic Product Claim Specialist

In just a few weeks we are off to In Cosmetics Paris, and the Suppliers will be there in full force to share with us (old-timers and newbies alike), their new ingredients, trends, as well as latest testing methods. With all these come the “claims”, and I hold my breath…

In recent years, the use of “small prints” in advertising, both on television and in print media, has become increasingly prevalent. These small disclaimers, often relegated to the bottom of advertisements or tucked away in inconspicuous corners, serve as a means to qualify and substantiate the bold claims made by brands. Yet, despite their intended purpose of providing clarity, small prints have sparked debates regarding their effectiveness and potential to mislead consumers, especially when it comes to interpreting statistical data.

Robert Langkjær-Bain’s insightful 2020 article, “Not buying it!” published in the esteemed journal Significance, offers a critical analysis of small print in advertising. Langkjær-Bain astutely points out that small print often raises more questions than it answers, highlighting the need for greater transparency and comprehension in advertising practices. While small print may seek to clarify claims, it must not contradict or undermine the primary assertions made in advertisements, as this can lead to consumer confusion and distrust.

Within the beauty industry, small print is frequently utilised to provide additional context or disclaimers regarding product claims. Marketers often rely on footnotes or fine print to qualify the efficacy or limitations of their products, especially in relation to consumer studies or scientific data. However, the challenge lies in ensuring that these disclaimers are clear, accessible, and do not detract from the main message conveyed in the advertisement. One of the primary concerns surrounding small print in beauty advertising is its potential to mislead consumers. While these disclaimers may offer valuable insights into the scientific research or testing conducted on a product, they often go unnoticed or are disregarded by consumers. Furthermore, the complexity of scientific language and terminology used in small print can further exacerbate confusion, leaving consumers uncertain about the true benefits or limitations of a product. Do we really need to have small print clarifiers claiming gene expression profiling by DNA micro-array in co-cultured fibroblasts”? How relevant is it to the consumer?

In recent years, there has been a growing emphasis on including pre-clinical data in small print disclaimers. These data may include in vitro studies, which examine the effects of a product on skin cells or tissue samples, or ex vivo studies, which utilise excised human skin for testing purposes. While such studies can provide valuable insights into the potential mechanisms of action or safety of a product, they may not accurately reflect how the product will perform in real-world settings or on a diverse range of skin types.

Moreover, small print disclaimers often lack the sensory data necessary to gauge consumer acceptance and satisfaction accurately. While scientific studies may demonstrate the biochemical or molecular effects of a product, they do not necessarily capture the subjective experience of using the product, such as it’s texture, scent, or overall feel on the skin. As a result, consumers may be left uninformed or misled about the true sensory experience of a product, leading to potential dissatisfaction or distrust in the brand.

With InCosmetics Paris only a few weeks away, promoting cosmetics based solely on pre-clinical studies presents several challenges and limitations. These studies, conducted in controlled laboratory settings, may not accurately reflect how a product will interact with human skin or bodies in real-world conditions. Furthermore, the translation of pre-clinical findings into human studies requires rigorous validation through comprehensive clinical and consumer trials. Clinical studies, are essential for assessing the safety, efficacy, and real-world performance of cosmetic products under diverse conditions and in representative populations. Consumer studies, meanwhile, provide valuable insights into consumer preferences, perceptions, and satisfaction with a product.

Despite the importance of clinical and consumer validation, small print disclaimers often fail to adequately convey the limitations of pre-clinical studies or the necessity for further research. Consumers may be misled into believing that a product is safe and effective based on preliminary scientific data, without sufficient evidence to support such assertions. Furthermore, small print disclaimers may lack the transparency and clarity necessary to ensure consumer comprehension and informed decision-making. The use of technical jargon or complex scientific language can alienate consumers and undermine their ability to understand the true benefits or limitations of a product.

Regulatory compliance is another important consideration when it comes to small print disclaimers in beauty advertising. Regulatory authorities, such as the Food and Drug Administration (FDA) in the United States or the European Commission in the European Union, impose stringent requirements for the safety and labelling of cosmetic products. These regulations typically mandate that cosmetic claims be substantiated by adequate scientific evidence, including clinical and consumer data where applicable. Therefore to avoid penalties and loss of credibility, it is essential for brands to ensure that their advertising practices are in compliance with applicable regulations and guidelines, e.g., the UK’s ASA/CAP rules on small print and footnotes: Marketing communications must not materially mislead or be likely to do so (Rule 3.1).  Qualifying information must: be included where it is material to the consumer’s understanding of the primary claim, or marketing communication as a whole (rule 3.3); must not contradict the primary claim being qualified to the extent that consumers are likely to be misled (rule 3.9); and must be presented clearly with an appropriate level of prominence (rule 3.10).

In closing, while small print disclaimers serve as a means to provide additional context or qualifications regarding product claims, they must be clear, accessible, and transparent to ensure consumer comprehension and informed decision-making. Furthermore, brands must prioritise clinical and consumer validation to substantiate their claims and ensure the safety and efficacy of their products. By adopting a holistic approach to advertising and marketing, brands can build trust and confidence with consumers, fostering long-term relationships and brand loyalty. And the statistics? As Langkjær-Bain points out “it seems that those pushing for action on statistics in adverts will have to keep doing so, perhaps without much support from the public they seek to protect”. In other words “one thing that would help both consumers and advertisers to make better judgements would be a firmer grasp of statistics”, and the Royal Society of Statisticians has also called for measures to increase statistical literacy — including improvements to school and university education, and developing statistical and data skills in the advertising industry workforce. We need it more and more in marketing too!

See you next month…and in Paris too!

Theresa Callaghan
Theresa Callaghan
Skin Care Scientist and Cosmetic Product Claim Specialist

Theresa Callaghan, a PhD biochemist with over 35 years of experience in corporate skin care research, has held key R&D senior roles for companies including LVMH, Unilever, Marks & Spencer, J&J, Evonik, Hill-Top Research, and proDERM. In 2008, she created Callaghan Consulting International, focusing on cosmetic claims development with brands and ingredient suppliers. She is a widely published author, frequent speaker, and contributor to peer-reviewed journals. Her acclaimed book, 'Help! I'm Covered in Adjectives: Cosmetic Claims & The Consumer', has gained popularity. She is a member of the Society of Cosmetic Scientists and British Herbal Medicine Association, and has lectured at the University of Sunderland's School of Pharmacy and Cosmetic Sciences. Theresa serves on the editorial peer review board of the International Journal of Cosmetic Science. She also mentors; advises TKS Science Publisher; and writes monthly for BEAUTYSTREAMS Ingredient Pulse; and has her own Cosmetic Claims Insights Column with EuroCosmetics.

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