Who: The Advertising Standards Authority (ASA) and 111 Skin Ltd t/a 111skin
Where: United Kingdom
When: 13 May 2026
Law stated as at: 3 June 2026
What happened:
The ASA has published a ruling against beauty brand 111skin, concluding that the product listing on its website for the “Exosome Face Lift” made efficacy claims that could not be substantiated and exaggerated the effects of the product.
The product listing included claims that the product targets fine lines and wrinkles. It claimed it was: “Clinically proven To Lift the Skin By 20**%”, with small print at the bottom of the page stating “**Clinical grading assessment using a 10-point scale conducted on 30 participants after 4 weeks of product use.” 111skin also claimed that the product: is “powered by exosomes which help boost and regenerate the skin barrier”; uses an “innovative microspicule delivery system which helps enhance the absorption of the active ingredients”; and “helps visibly lift and tighten the skin” and “visibly renew and rejuvenate the skin in 4 weeks”.
A complainant challenged whether the efficacy claims were misleading. The ASA investigated 111skin’s claims that the product was clinically proven to lift skin by 20% in four weeks, an impression that the ASA considered was reinforced by the product name “Exosome Face Lift” and other claims. The ASA also highlighted the accompanying explanatory text, “Powered by exosomes which help boost and regenerate the skin barrier” and “innovative microspicule delivery system which helps enhance the absorption of the active ingredients”. It considered that consumers would understand those claims to mean that the product produced a significant lifting effect, and that it contained “exosomes” which had an effect on the skin barrier when the product was applied. The ASA expected to see robust evidence to substantiate those claims.
111skin explained that the claims were supported by a study referenced in small print in the ad. The ASA found that the clinical study ran for 28 days across 30 subjects. While the ASA acknowledged high levels of agreement for questions relating to efficacy and the lifted aspect of the product, the study did not include a placebo or control group and comprised only 30 subjects. The ASA considered that the “lifted aspect” measure was based on a subjective clinical grading score as opposed to an objective measure of lift. The ASA also found that the objective measures in the tests (including skin roughness, firmness and texture) did not demonstrate a lifting effect to the extent implied by the claim “lift the skin by 20%”.
111skin also provided penetration and permeability testing to support its claims regarding an “innovative microspicule delivery system”. The ASA found that the test consisted of only a single participant, who applied the product to their arm rather than their face. The test was therefore considered insufficient to substantiate the claim. 111skin also failed to provide any evidence that the exosomes in the product produced the effects described in the ad. The ASA also considered that unqualified claims such as “rejuvenation” were not generally acceptable for cosmetic products.
Why this matters
This ruling is relevant to anyone advising on skincare or makeup campaigns or points of sale, including legal, product and marketing teams, and highlights that unsubstantiated efficacy claims, exaggeration and the cosmetics and beauty industry remain high on the agenda of the ASA.
Advertisers should continue to:
- Obtain or conduct a properly randomised, placebo-controlled study before using the phrase “clinically proven”. Advertisers should ensure the primary outcome measure of the study is objective and directly related to the claim made.
- When conducting a study, ensure that the sample size is appropriate and that the testing conditions reflect real use (if a facial product, the product should be tested on a subject’s face). A single subject is unlikely to be sufficient.
- Not assume that evidence of one cosmetic benefit (for example, improved texture) substantiates a different but related claim (for example, lifting). Each distinct claim needs its own supporting evidence.
- Not rely solely on footnotes or small text to qualify a headline claim that cannot otherwise be substantiated.
- When making a claim about an ingredient in the product, ensure they have evidence that the ingredient is present in an effective concentration and that the ingredient produces the claimed effect.
- Consider whether the product name itself may be construed as a marketing claim which might need substantiation or otherwise be subject to the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing rules.
