Bubble Beauty, Inc., is a skin care brand known for its affordable products and youth-centric branding. The joint decision related to Bubble’s express and implied claims on its products.
However, NAD and CARU recommended that the company discontinue claims about the efficacy of these products for children under 13.
Recent data reported by market research firm Statista revealed that in a survey of US parents, 68% confirmed their pre-teen children between ages seven and 11 had some sort of “skin care routine.” As the Gen Alpha demographic grows, so does youth-targeted skin care, which has gained significant attention in the last few years and raised concerns about the accuracy of claims made by beauty brands.
NAD and CARU’s inquiry into Bubble’s safety vs. efficacy claims
NAD and CARU initiated the inquiry due to Bubble’s marketing strategies, particularly its social media campaigns and Disney-branded product bundles, which target and “convey the message that Bubble cleansers, moisturizers, and SPF products have been tested on, and are both safe and effective for, young girls,” NAD’s press release stated.
As noted by NAD, “beauty advertising in the social space reaches tweens and teens at a time when their self-image is vulnerable and they are susceptible to pressure from peers, which reinforces NAD and CARU’s role in ensuring beauty brand claims are truthful and transparent.”
According to NAD’s press release, CARU determined that Bubble’s limited-edition Disney-branded product bundles were directed at children under 13, bringing them under CARU’s jurisdiction.
Following a review of independent reports and third-party research submitted by Bubble to support its marketing claims, NAD concluded that the evidence substantiated the company’s express and implied claims regarding product safety for users under 13.
However, NAD determined that the efficacy claims for Bubble’s cleansers and moisturizers were not adequately supported. Specifically, NAD stated that “the evidence is not a good fit to support these challenged efficacy claims.”
Regarding SPF products, NAD acknowledged that such claims are regulated by an FDA Monograph and noted that Bubble may continue to make SPF claims if they remain compliant with these regulations.
CARU’s review of Disney-branded bundles
CARU’s review focused on the packaging of Bubble’s limited-edition Disney-branded product bundles featuring characters from the upcoming Disney Pixar film Inside Out 2, whose launch was covered in CosmeticsDesign last year. Specifically, NAD’s press release confirmed that CARU examined whether the “claims made on the packaging could mislead children into believing the products were both safe and effective for them, and whether the claims could misrepresent that the products in the bundles could perform in a manner that they cannot.”
Drawing from NAD’s determinations, CARU concluded that safety claims for the serums in the bundles were supported but recommended Bubble discontinue efficacy claims for these products when marketed toward children under 13.
In response, Bubble maintained in an advertiser statement that while it “does not necessarily agree with all aspects of the NAD/CARU decision, Bubble will comply with NAD and CARU’s recommendations.”