NAD announced that Fenty Skin LLC has substantiated key performance claims for its Melt AWF Jelly Oil Makeup-Melting Cleanser, including:
- “From longwear or waterproof makeup, sunscreen, dirt, oil + impurities melt that… AWF in one go.”
- “This unique jelly texture gently delivers clean, nourished + conditioned skin without the stripping or drying.”
- “In a study of 52 people after 1 use, 100% agreed it gently cleanses skin leaving it clean and fresh, 96% agreed that it cleansed skin without stripping, 92% agreed it removes makeup.”
As confirmed in its recent press announcement, NAD “also concluded that product demonstrations featuring influencers were supported by the evidence and that the videos were accurate and not enhanced.”
However, in reviewing the brand’s advertising disclosures, NAD recommended that “Fenty Skin require its paid influencer, Crème Fatale, to modify a challenged Instagram post to include a clear and conspicuous material connection disclosure in the video demonstration itself, and that Fenty Skin’s re-post of this video to its own Instagram page should likewise have a modified disclosure,” according to the press release.
Determinations regarding product performance claims
Substantiation of Fenty Skin’s claims included independent clinical testing and consumer use surveys, alongside evidence on the mechanism of action for oil and oil-soluble cleansing substances, said the release. As a result, NAD “concluded that these results provided a reasonable basis for Fenty Skin’s claims” regarding product performance.
Further, NAD reviewed Melt AWF Cleanser product demonstrations by TikTok influencers Sarah Novio and Crème Fatale, which were re-posted on Fenty Skin’s company Instagram account. As reported in the release, NAD determined that Fenty Skin’s clinical and survey results substantiated the message that the Melt AWF Cleanser effectively breaks down and removes waterproof makeup in one application.
Determinations regarding endorsement disclosures
Despite NAD finding in favor of the company for its performance claims, it recommended modifications to the disclosure practices for influencer endorsements. Specifically, NAD suggested that “Fenty Skin require Crème Fatale to modify a challenged Instagram post to include a clear and conspicuous material connection disclosure within the video demonstration itself”, said the press release. Additionally, it was recommended that Fenty Skin’s re-post of this video should also include a modified disclosure.
During the review process, Crème Fatale’s Instagram was “updated to include both the ‘paid partnership’ disclosure and hashtags #ad and #sponsored in the caption,” the release reported. Similarly, Fenty Skin’s Instagram page was updated to include #AD in the caption. Despite these updates, NAD recommended further modifications to ensure clear disclosure within the video content itself.
Fenty Skin advised NAD that it had also requested Sarah Novio to update her TikTok and Instagram posts to include clear disclosures that she received the product for free, according to NAD’s press announcement. The brand “removed these posts from its own Instagram and will only re-post once the disclosure is corrected by Ms. Novio,” the release confirmed. For compliance purposes, NAD will treat this as if it had recommended the modification.
Conclusion and compliance
During the proceeding, Fenty Skin informed NAD that it had permanently discontinued using the term “clean” on product packaging and online platforms, so NAD did not review this claim on its merit, the release reported.
In its advertiser statement, Fenty Skin expressed its commitment to comply with NAD’s decisions and emphasized its support for the self-regulatory process and appreciation for NAD’s thorough review, the announcement concluded.
This finding by NAD highlights the importance of substantiated claims and transparent disclosure practices in influencer marketing, ensuring that consumers receive accurate and trustworthy information about cosmetic and personal care products.
