National Advertising Division and Children’s Advertising Review Unit Find Bubble Beauty Safety Claims Supported

Bubble Beauty, Inc.’s express and implied claims that its cleansers, moisturizers, SPF products and serums found in Disney-branded product bundles are safe for users under 13 are supported by the BBB National Programs’ National Advertising Division (NAD) and Children’s Advertising Review Unit (CARU).

However, NAD and CARU recommend Bubble discontinue express and implied claims that Bubble cleansers and moisturizers are effective on children under 13 years of age. Additionally, CARU recommend Bubble discontinue express and implied claims that serums found in the Disney product bundles are effective on children under 13.

NAD and CARU brought this inquiry jointly as Bubble’s social media posts and Disney-branded product bundles target both adults and young girls. CARU determined that Disney-branded Bubble Skincare product bundles are directed to children under age 13, falling under CARU’s jurisdiction.

Beauty advertising in the social space reaches tweens and teens at a time when their self-image is vulnerable and they are susceptible to pressure from peers, which reinforces NAD and CARU’s role in ensuring beauty brand claims are truthful and transparent.

NAD’s inquiry focused on Bubble’s social media advertisements that convey the message that Bubble cleansers, moisturizers, and SPF products have been tested on, and are both safe and effective for, young girls.

In support of its claims, Bubble provided a variety of independent reports and third-party testing and research. NAD found the evidence submitted supports the express and implied claim that Bubble’s cleansers, moisturizers and SPF products are safe for users under 13.

However, NAD recommended Bubble discontinue the express and implied claim that Bubble cleansers and moisturizers are effective on children under 13 years of age, as it determined the evidence is not a good fit to support these challenged efficacy claims. NAD recognized that SPF claims are regulated by an FDA Monograph and acknowledged that Bubble can make SPF claims if they comply with the regulations.

Misleading Packaging?

CARU’s inquiry sought to determine if the packaging of limited-edition product bundles, featuring characters from the Disney Pixar film Inside Out 2, complies with CARU’s Self-Regulatory Guidelines for Children’s Advertising. At issue for CARU was whether claims made on the packaging could mislead children into believing that the products in the bundles are both safe and effective for them and whether the claims could misrepresent that the products in the bundles could perform in a manner that they cannot.

Relying on NAD’s findings regarding the safety and efficacy of Bubble’s cleansers and moisturizers, CARU reviewed safety and efficacy data for the serums found in the Disney-branded product bundles and found the safety claims supported, but recommended Bubble discontinue express and implied claims that the products found in the Disney-branded bundles are effective on children under 13 years of age.

In its advertiser statement, Bubble stated that although it “does not necessarily agree with all aspects of the NAD/CARU decision, Bubble will comply with NAD and CARU’s recommendations.”