The Electronic Retailing Self-Regulation Program (ERSP) has recommended that Neemology modify specific performance and establishment claims in advertising for “DentaBoost.” Additionally, ERSP determined that the marketer could not support establishment claims or consumer testimonials.
ERSP, the electronic direct-response industry’s self-regulatory forum, is administered by the Council of Better Business Bureaus (CBBB) with policy oversight by the National Advertising Review Council (NARC).
The marketer’s advertising came to the attention of ERSP pursuant to its ongoing monitoring program.
ERSP reviewed broadcast and online advertising for DentaBoost and identified several claims for review, including:
- “Dental health is essential for overall health. DentaBoost contributes to superior dental health.”
- “DentaBoost has harnessed the power of Neem Complex to proactively: Promote healthy gums, Reduce fear of the dentist by making dental visits easier, Gently whiten teeth and contribute to a brighter smile, Instantly eliminate bad breath and give you a fresh, clean feeling, Give you that fresh from the dentist feeling.”
- “DentaBoost uses a unique combination of scientifically proven natural ingredients including our proprietary Neem Complex to instantly improve the health of your gums and overall oral hygiene.”
- “A major university study verifies the healthy benefits of one of the key ingredients in DentaBoost.”
- “DentaBoost is a natural way to whiten my teeth.”
DentaBoost is an oral hygiene powder consisting of neem that is applied to a toothbrush and which claims to contribute to good dental health. After reviewing the evidence in the record, ERSP did not object to general statements about the neem ingredient and its use to promote healthy gums or better dental health.
However, ERSP found that the more specific claims in the advertising (e.g., “acts as tooth whitener”; “[i]nstantly eliminate bad breath”; “[m]akes your tooth brush more effective”) were not supported by the study data submitted. ERSP also determined that the claim “[DentaBoost] makes your toothbrush more effective” can be interpreted to mean that DentaBoost will contribute to cleaner teeth. Neemology did not provide any evidence that DentaBoost has a significant effect on making a user’s teeth cleaner than toothpaste alone.
As support for the establishment claims at issue, Neemology submitted several studies on neem, the primary ingredient in DentaBoost. ERSP found the studies tested neem at different dosages and via different methods of administration as compared to DentaBoost, and did not adequately substantiate the establishment claims. Similarly, ERSP found that the marketer’s evidence did not support claims found in consumer testimonials, and recommended Neemology modify or discontinue such claims.
The company, in its marketer’s statement, said, “We have reviewed ERSP’s decision regarding direct response advertising for DentaBoost and although we may not agree with all you decisions, we will take your recommendations into consideration in future advertising.”
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