Who: The Advertising Standards Authority (ASA) and Viridian International Ltd (Viridian)
Where: United Kingdom
When: 30 July 2025
Law stated as at: 18 August 2025
What happened:
Viridian’s website and a press ad claimed that its vitamin supplement products contained “No Junk”. The website ad claimed that Viridian’s supplements contained “100% active ingredients (…) with no fillers, binders, glues, irradiation or lubricants from mass production – nothing!”. It also compared Viridian’s products with images of other mass-produced supplements, together with lists of their ingredients and a cross symbol next to each ingredient list. In addition to a claim of “No Junk” in Viridian products, the press ad also claimed that many supplements were “ultra processed” and contained “ineffective fillers”. Both ads contained text stating that Viridian’s products were “pure”.
Issue
The Health Food Manufacturers’ Association (HFMA) challenged Viridian’s claims that their supplements contained “no junk”, “100% active ingredients”, “only uses […] active ingredients” and were “pure,” thereby implying that they were not “ultra processed”. The HFMA argued that these claims were misleading and questioned whether they could be substantiated. It contended that the ads “discredited and denigrated” another product.
‘Pure’ and ‘No Junk’
Viridian argued that while there was no legal definition of the term “junk”, it was possible for legally permitted products to be determined “junk”. Viridian gave the example of “junk food”, which it said consumers understand to refer to food containing ingredients that are not “good for you”. Viridian also defined “pure” as something to which nothing had been added, and argued that the absence of fillers, binders, lubricants etc. justified this statement. The company also said that its own products did not contain the highlighted excipients (substances other than the active ingredient) and added ingredients.
However, the ASA considered that, in the context of ads referring to “pure” products, consumers were likely to understand “No Junk” to mean that Viridian’s products were of a higher quality than its competitors’ products. Further, Viridian’s use of carrier fillers and a cellulose shell were likely to be viewed by consumers as additional ingredients that contained no nutritional benefit. The word “pure” was likely to be understood as containing no additional ingredients whatsoever.
‘Ultra Processed’
Viridian argued that the implied claim that its products were not “ultra processed” was justified because they did not contain ingredients used to support the manufacturing and operations process, unlike others that contained preservatives, flavourings and colours.
The ASA disagreed, considering that consumers would likely understand that the products had undergone minimal processing to take them from the raw ingredient to a finished product. Viridian had not, however, demonstrated that the processing was minimal.
‘Active Ingredients’
As for the claim that Viridian products only contained “active ingredients”, Viridian contended that “active” is commonly defined as “working or engaging or ready to engage”. It argued that the capsule shells used in its supplements constituted an “active ingredient”, because they are necessary for the delivery of the supplement.
However, the ASA considered that, in the context of an ad for a food supplement, consumers were likely to understand that every ingredient was “active” and was included due to its nutritional or physiological effect on the body. Referring to the Food Supplements (England) Regulations 2003, which require products to specify the amount of any vitamin, mineral or other substance that has a nutritional or physiological effect, the ASA noted the absence of the specific quantities of cellulose capsules and carrier bases in Viridian’s ingredients lists, despite them being described as “base” products. In the ASA’s view, their inclusion in the table of ingredients, which listed the amount and nutrient reference value of each vitamin and mineral, demonstrated that they were separate from the nutrient content of the product, and therefore not “active ingredients” in the way that consumers would likely understand the term.
Because Viridian could not substantiate the above claims, the ASA held that the ads were misleading.
Comparing products
In addition, the ASA considered that, under the CAP Code, marketing communications must not discredit or denigrate another product or marketer. Despite Viridian flagging that its ads only used general language and digitally created images, as opposed to photographs, the ASA held that consumers were likely to associate the images with other products on the market and that the claims overall amounted to a comparison between Viridian products and the rest of the nutritional supplement market.
Further, the term “junk”, which the ASA considered was a pejorative term, suggested that Viridian products were better because they contained “pure” ingredients and did not include “fillers” as opposed to competitors’ products. In the ASA’s view, consumers would understand from Viridian’s claims that they should avoid those competitor products. In addition, the phrase “What On Earth is in Your Supplement?” created a “demeaning tone”. Because these references went beyond a factual and informative comparison, the ASA ruled that the ads discredited and denigrated other nutritional supplements.
Overall, the ASA upheld the HFMA’s claims, finding that Viridian’s ads breached the CAP Code.
Why this matters: The ASA’s ruling highlights the importance of substantiating advertising claims and avoiding misleading statements. Businesses must ensure that if they use terms like “pure”, “no junk” and “active ingredients”, they are backed by evidence and accurately reflect the product’s composition. Additionally, comparative advertising should be a factual and informative comparison, and must not discredit or denigrate competitors’ products, irrespective of whether the claims in relation to competing products are true.
