Who: Advertising Standards Authority (ASA) and TX UK Ltd t/a Zara
Where: United Kingdom
When: 6 August 2025
Law stated as at: 22 September 2025
What happened:
The ASA considered whether the models in four ads on Zara’s website appeared unhealthily thin. The ads featured images of:
- A model standing up wearing an oversized pocket shirt, with her right hand on her hip and her left hand in her pocket.
- The same model as in (a) wearing a contrasting ruffle body suit, with her body facing one way and her head slightly twisted in the other direction.
- A model wearing a voluminous combined short dress, standing up, with her arms down by her side.
- The same model as in (c) standing up wearing a pair of extra wide-leg high-waist jeans. Her stomach was partially visible, as were her arms, which were straight and positioned downwards in front of her legs.
Zara said that both models had medical certification which proved that they were in good health in line with the recommendations of “Fashioning a Healthy Future”, a report by the UK Model Health Inquiry, setting out recommendations to address concerns about unhealthily thin models. Recommendation three within that report states that models should provide a medical certificate attesting their good health from doctors with expertise in recognising eating disorders.
However, the ASA ruled that in two instances the models appeared unhealthily thin.
In ad (a), the ASA considered that the shirt’s low neckline drew focus to the model’s upper chest, creating a focal point on a protruding collarbone. The styling of the image made the collarbone appear to run alongside the shirt’s collar line, which accentuated the collarbone further. In addition, the positioning of the model’s arms in the oversized, baggy shirt created the impression that they were very slim, as were her shoulders and chest. Overall, the ASA concluded that the model’s pose and the choice of clothing in the ad created the impression that the model was unhealthily thin.
In ad (c), the ASA considered that the shadows cast on the model’s legs both highlighted them and made them look noticeably thin. Her hair was styled in a slicked back bun, drawing emphasis to her head and making it appear slightly gaunt. The contrasting positioning of her upper arms and elbows made her body appear slightly out of proportion, and the style of the dress made her collarbone visibly protruding. Taken together, the styling, lighting and clothing choices in the ad gave the impression that the model was unhealthily thin.
As for the other two ads, the ASA said that the models’ bodies appeared in proportion and were not presented as unhealthily thin overall:
- In ad (b), the ASA acknowledged that the model’s collarbone was visible, which likely appeared to be more prominent because of the position of her head, but concluded that the model’s face did not look gaunt and, although partly visible, her stomach, chest and arms showed no protruding bones. Her legs were not visible in the image.
- In ad (d), the baggy jeans worn by the model created the impression that her legs were slim. Further, the lighting drew attention to the bones in her hands and, because her arms were cut off in the image, they appeared longer and slimmer than they might have been. However, the model’s body was presented as being in proportion. Her stomach, mostly covered by a shirt, did not look gaunt and the image featured no protruding bones.
Why this matters:
In an article discussing its recent rulings on portraying models as unhealthily thin looking (for example, Next and Marks and Spencer), the ASA says that similar complaints to the ASA are on the rise and now average five or six a week, demonstrating public concern in this space. The article, originally published in The Drum on 9 September 2025 and reproduced on the ASA’s website with permission, notes that societal attitudes towards the “ideal” female body shape have always moved around and there are currently signs pointing towards a shift back to “skinny” models.
When assessing these ads, the ASA explains that it focuses on how the models are depicted and the likely impact on audiences, rather than on the models’ actual health. The advertising rules do not ban thin or lean models per se, but certain creative choices, such as lighting, styling, makeup, posture and camera angles, can make models appear thinner than they are and can potentially render an ad irresponsible. These problems can be avoided, however, by making different creative choices. This Zara ruling illustrates these points, with the same model being judged unhealthily thin in one ad, but proportionate in another.
Within this particular article, the ASA also explains why it addresses the depiction of thinness in models, but not models who appear unhealthily overweight. The key factor is social context: in the UK, thinness is frequently portrayed as aspirational, while overweight body types generally are not. Although the ASA receives complaints about ads featuring models who may appear unhealthily overweight, it has not, so far, had grounds to investigate these because the ads in question did not promote such body types as ideals to aspire to – expressly or by implication. In fact, the ASA notes, including larger and different body shapes is often viewed as offering a positive, more inclusive narrative in fashion that challenges the notion that only thinness is desirable.
The ASA’s message to industry is: “be aware of what impact your creative choices may have on different audiences.” The regulator says that it will continue to hold advertisers to account, and that “creativity should never come at the expense of people’s mental or physical wellbeing”.
