Who: Committee of Advertising Practice (CAP)
Where: United Kingdom
When: 5 June 2025
Law stated as at: 14 August 2025
What happened:
“Before and after” photos have become more popular in recent years, especially on social media, and are commonly used in ads for beauty and cosmetic products, slimming products, diet plans and hair loss treatments. However, there are many traps marketers can fall into when using such claims. CAP has produced an advice note providing advertisers with some tips on how to comply with the advertising rules when making such claims.
Evidence matters
First, the photos must be genuine. Secondly, advertisers must be able to provide “signed and dated proof” that the images are indeed genuine, have not been manipulated and represent the effect that consumers could likely expect from the product or treatment. Adverts must not exaggerate the product’s efficacy.
CAP highlights this in a separate note, examining various Advertising Standards Authority (ASA) rulings in the area of cosmetic and beauty advertising. One of the ads considered was for a mask stick for blemishes and acne removal. It showed the product causing a “near-instantaneous and dramatic” clearing of the models’ skin blemishes, which led the ASA to consider that the “before and after” photos used in the ad were filtered. Since the advertiser was unable to demonstrate that the images represented the effect consumers could expect and that the images were unaltered, the ASA considered the ad to be misleading.
When making health, beauty and slimming claims in ads, marketers need to be aware of CAP’s guidance setting out the types of evidence required to substantiate the claims and understand that the regulators treat “before and after” photos as testimonials under the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code).
Use of pre- and post-production techniques
CAP’s guidance on the use of pre and post-production techniques provides more clarification on when “before and after” photos in ads for cosmetic products can be used legitimately and when they can be considered misleading. It addresses pre-production techniques, such as styling, make-up, eyelash and hair extensions, as well as post-production techniques such as digital retouching, both of which are often used in before and after imagery.
It is not prohibited to use such techniques in general and no explicit disclosure is needed, provided such techniques do not mislead by exaggerating the effect of the product. For example, in terms of pre-production techniques, in ads for mascara, lash extensions should not be used to create a lengthening or volumising effect not achievable by the mascara itself. However, lash extensions may be used to fill in natural gaps in the lash-line and thereby help achieve a uniform lash-line effect to which the mascara is then applied. Using pre-production techniques on “after” images only, however, would likely be considered misleading.
As for post-production techniques, such as photographic retouching, extra care is needed to avoid misleading consumers. Making changes digitally, for example, removing or reducing the appearance of lines and wrinkles around the eyes for an eye cream ad or digitally increasing the volume of eyelashes for mascara, is likely to be considered misleading.
In both cases, advertisers must keep in their possession material demonstrating any alterations, including “before” and “after” images showing the effect of both pre- and post-production techniques.
Health claims, medical devices and prescription-only medicines
Marketers using “before and after” photos should also remember that some products might be subject to additional advertising requirements. For example:
- Claims for medical devices (such as weight-loss apparatus, lasers, circulation boosters) can only be made for appropriately certified medical devices.
- Prescription-only medicines (such as Botox) cannot be advertised to the public. “Before and after” imagery of a prescription-only product, even used in isolation without any accompanying claims, is likely to be seen as an implied ad for a prescription-only product, and therefore a breach of the advertising rules.
- Slimming or health claims in ads for health products, such as slimming teas and food supplements, need to be authorised on the Great Britain nutrition and health claims register.
Slimming claims
Further care should be taken when advertising diet or exercise plans using “before” and “after” images. Obesity is frequently associated with medical conditions, and the CAP Code states that marketers must not discourage essential treatment for which medical supervision should be sought. Marketers should not imply that they can offer treatment for obesity by showing “before” images, unless the diet or exercise plan being advertised is supervised by a suitably qualified health professional. Holding robust evidence for the efficacy of any slimming regime is crucial.
Disclaimers and qualifications
Using superimposed qualifications or disclaimers – for example, stating that certain pre and post-production techniques have been used in “before” and “after” images – does not mean that advertisers are free to use otherwise disallowed activities or techniques. If the ad is inherently misleading, it remains so regardless of whether any disclaimer or qualification is used.
Why this matters:
“Before and after” images in beauty and cosmetic ads can be a useful marketing tool to showcase a product’s qualities, but they must always be genuine and reflect genuine results that consumers may expect to achieve. Additionally, it is not prohibited to use filters, pre- or post-production, or other techniques in “before and after photos”, but they must not be used to exaggerate the effect or efficacy of a product. Using disclaimers and qualifications should not be seen as a way round the rules – they do not excuse the use of misleading techniques. The rules are clear: advertising claims must not mislead and marketers must hold robust, documented evidence to substantiate their claims.
