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A listing for an “APPLE ACV KOMBUCHA DRINKS CUBE” featured the claim “Gently energising and rejuvenating”. We considered the claim that garlic “has reports of helping to lower blood pressure” and that ginger “can help fight high blood pressure” in ad (b) would be understood to mean those ingredients in the Fire Cider product could reduce high blood pressure. Because high blood pressure was a risk factor in the development of a range of diseases, we considered the claims were therefore reduction of disease risk claims. The CAP Code prohibited claims that stated or implied that a food could prevent, treat or cure human disease.Ad (a) included the claims “Can shrink swelling in the body” and “Anti-inflammatory”; ad (b) included the claim “Turmeric and Cayenne pepper – turmeric is known to contain anti-inflammatory properties” and the claim “Loaded with […] anti-inflammatory properties” in relation to the Fire Cider product; and ad (c) included the claims “loaded with […] anti-inflammatories” and “Overall loaded with anti-inflammatory properties”. We considered those claims would be understood to mean the product could help to treat inflammation in the body, and were therefore claims to treat or cure human disease. We welcomed Willy’s ACV’s assurance that the claims would be amended. However, because the ads made claims to prevent, treat or cure human disease, we concluded they breached the Code. Because we had not seen any evidence that the specific health claims in ads (a), (b), (c), (e), and (f) were authorised on GB NHC Register, and ads (a), (b), (c) and (d) made general health claims that were not accompanied by specific authorised health claims, we concluded they breached the Code.
ads (a), (b), (c), (d), (e) and (f) made general and specific health claims that were in breach of the Code; ads (a), (b), (c), (d) and (e) made claims to prevent, treat or cure disease, which were prohibited by the Code; and The post went on to include as helpful tips “Rebalance your microbes by eating a diverse diet rich in live and fermented foods/drinks […] Because our ACV is alive with our 300 year old mother, getting your daily dose of ACV can help to repopulate some of the good bacteria in your gut”. Issue We then assessed which claims were general health claims, which therefore must be accompanied by an authorised specific health claim on the GB NHC Register.
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Willy’s ACV had not provided evidence that their products contained any foods or nutrients for which there were authorised reduction of disease risk claims on the GB NHC Register. We therefore concluded that the claims relating to the lowering of cholesterol and blood pressure breached the Code. On that point, ad (a) breached CAP Code (Edition 12) rules 15.6 and 15.6.6 (Food, food supplements and associated health or nutrition claims). Action Ads (b) and (c) included the claim “loaded with antioxidants”, and ad (b) also included the claim “Ginger – loaded with antioxidants” in relation to the Fire Cider product. We considered those claims were specific health claims that the products, or ingredients in them, helped to protect cells from oxidative stress. Ad (f) stated that “billions of cells including bacteria […] reside in our guts and are responsible for many vital bodily processes. This includes things like: helping to control digestion […] Our good gut bugs are important for digestion and destroying any harmful bacteria that may emerge […] certain factors […] can lead to gut dysbiosis”. In that context, we considered the claim that Willy’s ACV could “help to repopulate some of the good bacteria in your gut” would be understood to mean that the presence of “good” bacteria, provided by Willy’s ACV products, could help the process of digestive transit and counter any ill effects of gut dysbiosis. Similarly, we considered the claim “Help balance ph[sic] in the gut, leading to improved digestion” in ad (a) implied that the pH balance of the gut could be unbalanced and that if it was, digestion might be negatively affected, and that the product could help to correct that and improve digestive transit. We further considered the claims “can also help with digestion” in ad (b) and “boost digestion” in ad (c) would also be understood to mean the product could improve digestive transit. Claims to help or improve the process of digestive transit were specific health claims.
We considered the claims “play a part in bone and heart health” in ad (c) and “improving heart health” in ad (d) were references to the products promoting general good health of the bones and heart. We considered the claims “Good gut” and “gut-healthy goodness” in ad (a) and “#GutHealth” in ad (b) would be understood as meaning that the products were good for the overall general health of the gut. We considered the claims “Live probiotic foods” in ad (a) would be understood similarly, because consumers were likely to understand the word “probiotic” as describing a substance that contributed to the general good health of the gut. For the same reasons we considered the claim “with premium live probiotics to boost gut health” in ad (a) would also be understood as a reference to general health of the gut. All the above claims were therefore general health claims for the purposes of the Code. However, none of the claims were accompanied by relevant, authorised specific health claims as was required. The CAP Code defined health claims as those that stated, suggested or implied that a relationship existed between a food category, a food or one of its constituents and health. Willy’s ACV had provided third-party articles in support of the health claims made in the ads. However, only specific health claims authorised on the Great Britain nutrition and health claim (NHC) register (the GB NHC Register) could be made in ads promoting food or drink products. Any authorised health claims made in an ad must meet the associated conditions of use. Additionally, the Code required that general health claims, which were claims that referred to the general benefits of a nutrient or food for overall good health or health-related well-being, must be accompanied by a specific authorised health claim. Ad (a) also included the claim that Sir Ranulph Fiennes had said apple cider vinegar “helped relieve his arthritis symptoms” and ad (d) stated “Apple cider vinegar (ACV) has been used as a natural remedy for centuries – […] helping arthritis symptoms”. We considered those were claims that apple cider vinegar could help to treat a human disease. Willy’s ACV stated that they would, if the substantiation provided was deemed unsuitable, make changes, in particular to the claims about reduction of disease risk, and claims to prevent, treat or cure disease. Assessment We considered the claims “I feel better than I have for years”, “feel the difference to your wellness”, “to help you feel fantastic”, “daily dose of natural goodness”, “I can vouch for the benefits myself, it’s changed my life”, “Gently […] rejuvenating” and “wellness tonic” in ad (a) were references to how apple cider vinegar products provided general good health. We considered the claim “promote healthy aging” in ad (b) would be similarly understood, although in the context of aging in particular.Ad (e) included the claims “great for curbing sugar cravings” and “may also regulate blood sugar and insulin levels, which can lead to a reduction in sugar cravings”. We considered the claims would be understood to be specific health claims that the product could support the body’s ability to process sugar, and so support the regulation of blood glucose and insulin levels and increase feelings of satiety, particularly in relation to sugar consumption. Add into most meals including coups, salads, roasted veg and meat basting. Use in sauced, dressing, dips and marinades. Whizzy Salad Dressing The CAP Code stated that only reduction of disease risk claims authorised on the GB NHC Register could be used in marketing communications. Reduction of disease risk claims were health claims that stated, suggested or implied that the consumption of a food or one of its constituents significantly reduced a risk factor in the development of human disease. Enjoy a daily dose first thing in the morning or 30 minutes before meals. Take 25ml diluted in a smoothie, in warm water with lemon and honey or in other creative ways. Salt/Caffeine Swap Ad (a) included the claims “Helped me lower my cholesterol” and “I have lowered my cholesterol”; ad (b) included the claim that the garlic in the Fire Cider product “has reports of […] lowering cholesterol"; and ad (d) featured the claim that apple cider vinegar had been used as a natural remedy for “reducing cholesterol levels”. We considered consumers would understand those claims to mean that the apple cider products could reduce levels of cholesterol. High cholesterol was a risk factor in the development of heart disease and the claims were therefore reduction of disease risk claims.
Ad (b) also included the claim that cayenne pepper was “beneficial against infections” and ad (e) featured the claim “antimicrobial”. Antimicrobials were substances that killed microorganisms or prevented them from growing and causing disease. We therefore considered both claims would be understood as meaning the products could prevent viral and bacterial infections, and therefore were claims to prevent, treat or cure human disease. On that point, ads (a), (b), (c), (d), (e) and (f) breached CAP Code (Edition 12) rules 15.1, 15.1.1, and 15.2 (Food, food supplements and associated health or nutrition claims). We considered the claim “speed up your metabolism” in ad (b) would be understood to mean the product would speed up the metabolism, and that in turn would help with weight management and weight loss. Ad (a) also included the claim that the product “helped … lose weight”. Those claims were specific health claims.Ad (b) included the claim “Horseradish – known to boost circulation […]” in relation to the Fire Cider product. Ad (a) featured the claim “I sleep better” and the claims “increased my energy levels” and “Gently energising”. We considered that claims to boost circulation, improve sleep and increase energy levels were specific health claims. Rhian Stephenson, nutritionist, ex-CEO of Psycle and founder of supplements brand Artah Health, has felt the effects herself and fully supports a daily dosage of apple cider vinegar. “Personally, I find that it helps with my digestion and blood sugar control, especially when I'm overtired. Apple cider vinegar isn't a magic bullet, but it does have proven benefits when it comes to blood sugar regulation, postprandial insulin response, appetite and satiety, and potentially, managing cholesterol levels." We considered some consumers may not be familiar with the term “adaptogens”, used in ad (a). However, we understood the term was used to describe natural substances believed to help the body respond to stress, and we considered many consumers who were interested in the potential health benefits of products such as apple cider vinegar would have some knowledge of that definition. We therefore considered the claim “[…] with adaptogens” would be understood to mean that the product would support the body’s ability to respond to stress, which we considered was a specific health claim. On that point, ads (a), (b) and (d) breached CAP Code (Edition 12) rules 15.6 and 15.6.2 (Food, food supplements and associated health or nutrition claims). Ditch the salt and splash some apple cider vinegar into your meal to enhance the taste. Replace caffeine with an energising warm drink with ACV. Drizzle Over Meals
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