ERSP is an investigative unit of the advertising industry’s system of self-regulation and is administered by the Council of Better Business Bureaus. The marketer’s advertising came to the attention of ERSP pursuant to its ongoing monitoring program.
ERSP reviewed broadcast and online advertising for iGrow and identified several claims for review, including:
- “Keep the hair you have, no matter what genetics say. iGrow can help you delay the appearance of premature hair loss, and maintain strong, healthy hair through the years.”
- “Within 12 weeks of using iGrow™ as directed, most consumers report that they experience the cessation of excess hair loss. The appearance of thicker, fuller, and healthier hair is typical within 24 weeks (6 months) of LLLT.”
- “Studies proved that hair responds best to red light in the 650 - 670 nm wavelength range.”
- “...provides consistent, full scalp coverage to ensure optimal results.”
- “The iGrow can be used by anyone, men, women, any age, anyone with hair loss or hair thinning or worried about losing their hair.”
- “It’s proven: Most men and women prone to genetic hair thinning will benefit from low-level lasers. It's an amazing technology that can rejuvenate hair or delay the onset of thinning hair.”
As support for the performance and establishment claims at issue in the
inquiry, Apira Science submitted several studies on the effects of low-level
laser therapy (LLLT), the main technology behind iGrow.
Following its review of the evidence in the record, ERSP determined that
the marketer provided adequate substantiation for its general claims of product
efficacy and its safety claim. However, ERSP found that the evidence could not
support claims regarding the effectiveness of the iGrow on women and users of “any
age.”
Further, ERSP noted inconsistencies within the advertising regarding
the amount of time in which consumers can expect to see results.
ERSP also found the marketer was unable to support the claim that iGrow
“…has an equivalent output to most in office hair lasers” and will revitalize
hair on the sides of the head. ERSP
recommended the marketer modify or discontinue these claims.
The company, in its marketer’s statement, said “Apira
Science, Inc. appreciates the opportunity to participate in the Electronic
Retailing Self Regulation Program's ("ERSP") self-regulatory process
… We will make appropriate modifications to advertising for iGrow in accordance
with ERSP's recommendations.”
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