Who: Committee of Advertising Practice (CAP) and Advertising Standards Authority (ASA)
Where: UK
When: 18 August 2016
Law stated as at: 6 September 2016
What happened:
Ads for cosmetic surgery are a hot topic. Whether for surgical procedures, such as breast augmentation, or non-surgical interventions, such as injectable fillers, an increasing number of ads are coming under the ASA’s scrutiny. As such, CAP has released a note as a reminder to advertisers of cosmetic surgery to take particular care with these types of ads. The note recommends that advertisers take into account the following issues:
- Target audiences. CAP is of the opinion that young people are likely to interpret ads in a different way to adults. So particular care needs to be taken with regards to target audiences. Advertisers should not exploit the fact that younger audiences are more likely to identify with negative feelings about their appearance. For example, ads depicting people who were unhappy with their appearance, but who have now experienced a significant positive change in their emotional wellbeing as a result of a procedure could be held to be socially irresponsible. Anything which explicitly or impliedly links surgery with popularity or success should be avoided.
- “More natural appearance”. Ads which promote surgery to make a particular body part “more natural” in appearance are a risk. Depending on the context, certain body characteristics may in fact not be “unnatural” in appearance. Stating that a particular defect or bodily feature can be amended to make it more natural can be acceptable, but it will likely depend on the bodily feature in question.
- Promotional marketing. Given the nature of cosmetic interventions, which have the potential to be invasive, consumers should not be rushed into committing to a procedure or responding to an offer within a short time-frame. As such, advertisers are urged by CAP to avoid imposing short response times (e.g. “offer ends midnight”). Even if the promotion has been available for some time, it could be problematic if consumers only see ads towards the end of a promotional period and are forced to act fast. Consumers should be given enough time to research and give serious consideration before committing to cosmetic intervention. This could impact on promotions which, for example, give a limited time within which people can buy a voucher. The CAP note also goes on to say that the Royal College of Surgeons suggests that cosmetic services should not be offered as prizes and advertisers should not use promotional techniques or financial inducements which could influence a patient’s decision to have surgery.
- Avoid trivialisations. The ASA has clamped down on ads which trivialise procedures by implying that they are quick and simple. Examples given in the CAP note include an ad which implied consultations could be incorporated into Christmas festivities and an ad which included a testimonial for a breast procedure which commented on the ‘tiny’ incisions and stated that ‘you recover within hours’.
Why this matters:
The nature of cosmetic interventions are such that the requirement in the CAP Code to ensure that marketing communications are socially responsible could easily be breached. Anything which pressurises consumers to make a decision should be avoided. The CAP note should be read alongside the more thorough CAP Help Note on the Marketing of Cosmetic Interventions, which can be found here.
