Who: The Advertising Standards Authority (ASA), Beautaholic Ltd (Beautaholic), Invention Works BV (Invention), Luyors Retail Inc (Luyors) and Project E Beauty LLC (Project E)
Where: United Kingdom
When: 5 November 2025
Law stated as at: 21 November 2025
What happened:
The ASA has issued four beauty-related rulings as part of its wider work on LED facemasks for skincare.
The ads investigated were published on social media by Beautaholic, Invention, Luyors and Project E. The ASA challenged whether the ads made medical claims for an unauthorised medical device product.
In these rulings, the ASA emphasised rule 12.1 of the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code), which states that medicinal or medical claims can only be made for products that are: (1) licensed by the Medicines and Healthcare products Regulatory Agency (MHRA), the Veterinary Medicines Directorate (VMD) or under the auspices of the European Medicines Agency (EMA); or (2) a medical device that has the applicable conformity marking. In addition, a medical device should be registered with the MHRA before being placed on the market.
Claims such as “this mask provides targeted solutions for […] acne, […] rosacea […]” and “it helps tackle everything from acne […] with clinical precision” were considered by the ASA to be medical claims, as they suggested that the product could prevent or treat acne and rosacea, both recognised medical conditions. As the products advertised did not meet MHRA licensing and registration requirements, such medical claims were in breach of the CAP Code. The ASA informed the companies in their rulings that any future medical claims must be for products licensed by the MHRA (or VDM/EMA) and must have an applicable conformity marking.
Why this matters:
These rulings demonstrate that the making of unlicensed medicinal or medical claims in the cosmetics and beauty industry is still high on the agenda of the ASA, as well as other regulators. Marketers should:
- Ensure that any medical claims made in advertisements for products or devices are only made in relation to MHRA licensed products and, in the case of medical devices, products that have the applicable conformity marking.
- Continue to monitor their beauty and skincare ads for unauthorised medical claims and expect the ASA to continue targeting beauty-tech and skincare ads that claim they can prevent or treat medical conditions without appropriate licensing or conformity marking.
- Maintain up-to-date regulatory documentation to support any claims made in the event of an ASA enquiry.
Sophie Powell, a solicitor apprentice with Osborne Clarke, contributed to this article.
