National Advertising Division Finds Certain Revlon ColorSilk Claims Supported; Recommends Revlon Modify or Discontinue Others

New York, NY – January 29 – In a challenge brought by competitor Henkel Corporation, BBB National Programs’ National Advertising Division found certain claims supported but recommended that Revlon Consumer Products LLC modify or discontinue other claims for its Revlon ColorSilk with Bond Repair Complex product.

Henkel challenged express and implied claims made on product packaging, Revlon’s website and social media pages, and on third-party retailer sites such as Target.

Bond Repair Complex Claim

As support for its “with Bond Repair Complex” claim, Revlon submitted tensile strength and hair penetration studies for the key active ingredients in the ColorSilk product.

The National Advertising Division (NAD) determined that Revlon’s evidence provided a reasonable basis for the claim that Revlon ColorSilk is made “with a Bond Repair Complex.”

“Repairs Hair from the Inside Out”

NAD found that the performance claim “repairs hair from the inside out” conveys the message that the product produces significant if not complete repair of the hair fiber. While the totality of the evidence does show some level of cortex penetration by the product’s ingredients, NAD found it is not robust enough to support the broader message of “repair from the inside out.”

Therefore, NAD recommended that the claim “repairs hair from the inside out” be discontinued.

“Up To” Performance Claims

“Up to 98% Less Breakage”

Both Revlon and Henkel provided anti-breakage studies. NAD determined Revlon’s study was reliable and that the differences in results were not excessive and could reasonably be attributed to differences in testing apparatus, number of combings, and other protocol variables, and concluded that Henkel did not present stronger evidence or demonstrate that Revlon’s testing was fatally flawed.

Therefore, NAD determined that Revlon had a reasonable basis for its “up to 98% less breakage” claim.

“Up to 94% Smoother” and “Up to 94% Silkier”

Revlon submitted a wet combing study, which showed a 94.9% reduction in combing force for hair treated with the ColorSilk system versus untreated hair. NAD determined the study was reliable; however, NAD noted that in light of the imagery accompanying the claims, consumers could interpret unqualified claims as applying to dry hair, a claim for which Revlon provided no support. NAD therefore recommended that Revlon discontinue the “up to 94% smoother” and “up to 94% silkier” claims or modify its advertising to clearly indicate the basis of the claim through qualifying language or contextual cues.

“[Up to] 9x Shinier”

Revlon voluntarily agreed to modify the “9x shinier” claim by:

• Revising its packaging and advertising so the “up to” qualifier more clearly applies to both the “94% smoother” and “9x shinier” claims; and
• Including a disclaimer explaining the claim is based on testing for Revlon’s Medium Brown shade and that shine results may vary depending on shade selected.

In support of its claim, Revlon submitted a study comparing shine values of untreated hair to hair treated with the ColorSilk system in the Medium Brown shade. Henkel also submitted a shine test.

NAD determined that the Revlon study reliably measured shine under consumer-relevant conditions, and that the differences between the parties’ results could be attributed to differences in testing apparatus, and other variables.

Before and After Photographs

NAD considered the challenged implied claim that “Before and After pictures are authentic and represent typical and expected performance benefits for multiple hair types and colors.”

NAD determined that Revlon’s assurances as to the authenticity of the photos, and the fact that the images did not appear on every ColorSilk box, coupled with Revlon’s commitment to include a disclosure that the claim is based on testing of the Medium Brown shade and that results may vary by shade, adequately addressed Henkel’s concerns. Therefore, NAD concluded that the challenged implied claim is supported.

During the proceeding, Revlon also stated it would modify influencer content by adding a clear and conspicuous material connection disclosure. NAD did not review the modification on its merits and for compliance purposes, will treat the modification as though NAD recommended it and Revlon agreed to comply.

In its advertiser statement, Revlon stated it “agrees to comply with NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than 20 globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create fair competition for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About the National Advertising Division: The National Advertising Division (NAD) of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. NAD reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and create fair competition for business.  

National Advertising Division Finds Certain Revlon ColorSilk Claims Supported; Recommends Revlon Modify or Discontinue Others

New York, NY – January 29 – In a challenge brought by competitor Henkel Corporation, BBB National Programs’ National Advertising Division found certain claims supported but recommended that Revlon Consumer Products LLC modify or discontinue other claims for its Revlon ColorSilk with Bond Repair Complex product.

Henkel challenged express and implied claims made on product packaging, Revlon’s website and social media pages, and on third-party retailer sites such as Target.

Bond Repair Complex Claim

As support for its “with Bond Repair Complex” claim, Revlon submitted tensile strength and hair penetration studies for the key active ingredients in the ColorSilk product.

The National Advertising Division (NAD) determined that Revlon’s evidence provided a reasonable basis for the claim that Revlon ColorSilk is made “with a Bond Repair Complex.”

“Repairs Hair from the Inside Out”

NAD found that the performance claim “repairs hair from the inside out” conveys the message that the product produces significant if not complete repair of the hair fiber. While the totality of the evidence does show some level of cortex penetration by the product’s ingredients, NAD found it is not robust enough to support the broader message of “repair from the inside out.”

Therefore, NAD recommended that the claim “repairs hair from the inside out” be discontinued.

“Up To” Performance Claims

“Up to 98% Less Breakage”

Both Revlon and Henkel provided anti-breakage studies. NAD determined Revlon’s study was reliable and that the differences in results were not excessive and could reasonably be attributed to differences in testing apparatus, number of combings, and other protocol variables, and concluded that Henkel did not present stronger evidence or demonstrate that Revlon’s testing was fatally flawed.

Therefore, NAD determined that Revlon had a reasonable basis for its “up to 98% less breakage” claim.

“Up to 94% Smoother” and “Up to 94% Silkier”

Revlon submitted a wet combing study, which showed a 94.9% reduction in combing force for hair treated with the ColorSilk system versus untreated hair. NAD determined the study was reliable; however, NAD noted that in light of the imagery accompanying the claims, consumers could interpret unqualified claims as applying to dry hair, a claim for which Revlon provided no support. NAD therefore recommended that Revlon discontinue the “up to 94% smoother” and “up to 94% silkier” claims or modify its advertising to clearly indicate the basis of the claim through qualifying language or contextual cues.

“[Up to] 9x Shinier”

Revlon voluntarily agreed to modify the “9x shinier” claim by:

• Revising its packaging and advertising so the “up to” qualifier more clearly applies to both the “94% smoother” and “9x shinier” claims; and
• Including a disclaimer explaining the claim is based on testing for Revlon’s Medium Brown shade and that shine results may vary depending on shade selected.

In support of its claim, Revlon submitted a study comparing shine values of untreated hair to hair treated with the ColorSilk system in the Medium Brown shade. Henkel also submitted a shine test.

NAD determined that the Revlon study reliably measured shine under consumer-relevant conditions, and that the differences between the parties’ results could be attributed to differences in testing apparatus, and other variables.

Before and After Photographs

NAD considered the challenged implied claim that “Before and After pictures are authentic and represent typical and expected performance benefits for multiple hair types and colors.”

NAD determined that Revlon’s assurances as to the authenticity of the photos, and the fact that the images did not appear on every ColorSilk box, coupled with Revlon’s commitment to include a disclosure that the claim is based on testing of the Medium Brown shade and that results may vary by shade, adequately addressed Henkel’s concerns. Therefore, NAD concluded that the challenged implied claim is supported.

During the proceeding, Revlon also stated it would modify influencer content by adding a clear and conspicuous material connection disclosure. NAD did not review the modification on its merits and for compliance purposes, will treat the modification as though NAD recommended it and Revlon agreed to comply.

In its advertiser statement, Revlon stated it “agrees to comply with NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than 20 globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create fair competition for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About the National Advertising Division: The National Advertising Division (NAD) of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. NAD reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and create fair competition for business.  

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Job Title: Media Relations
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