Red Light, Green Light: ASA Blocks Acne Claims in LED Mask Ads

On 5 November 2025, the ASA published four rulings against retailers of LED face masks — Beautaholics Ltd, Invention Works BV (t/a Silk’n), Luyors Retail Inc, and Project E Beauty LLC — for making unauthorised medicinal claims. These decisions form part of a broader ASA initiative targeting misleading skincare ads that blur the line between cosmetic and medical claims.

The Issues

Each advertiser was found to have breached the CAP Code by making claims that their LED masks could treat medical conditions such as acne and rosacea. The ASA upheld complaints on the following grounds:

1. Medicinal Claims for Unlicensed Products
   All four advertisers made claims that their LED masks could treat or prevent acne — a recognised medical condition — without the products being registered with the MHRA or bearing the required conformity markings.

   • Beautaholics Ltd claimed “clinically proven light therapy […] targeting […] acne” and “targeted solutions for […] rosacea” (Beautaholics Ltd - ASA | CAP).

   • Silk’n featured a testimonial stating “Finished with the blue light to help treat my acne and scars” (Invention Works BV - ASA | CAP). 

   • Luyors Retail Inc advertised “clinical precision” in tackling acne (Luyors Retail Inc - ASA | CAP).

   • Project E Beauty LLC claimed “83% improvement in acne lesions in 4 weeks” and “HEAL ACNE” (Project E Beauty LLC - ASA | CAP). 

2. Use of Testimonials and Before/After Imagery
   Several ads relied on user testimonials and visual comparisons to imply medical efficacy. The ASA reiterated that such content must not be used to circumvent the rules on medicinal claims.

3. Misinterpretation of Cosmetic vs Medical Language
   Advertisers attempted to justify terms like “acne-related redness” or “targeted acne treatment” as cosmetic. The ASA disagreed, stating these were medical claims requiring regulatory approval.

When Cosmetic Becomes Clinical

The ASA’s rulings reinforce a clear boundary: cosmetic products must not stray into the territory of medical treatment unless they meet strict regulatory standards. Under CAP Code rule 12.1, advertisers may only make medicinal claims for products that are either:

• Licensed by the Medicines and Healthcare products Regulatory Agency (MHRA), Veterinary Medicines Directorate (VMD) or under the auspices of the European Medicines Agency (EMA); or

• For a medical device with the applicable conformity marking.

Even well-intentioned references to “healing” or “clinical precision” can tip an ad into non-compliance. The ASA’s use of AI-powered monitoring tools also signals a shift toward proactive enforcement, especially in fast-moving sectors like beauty tech.

What Retailers Need to Know

These rulings are part of a broader ASA crackdown on LED facemasks and similar devices. Retailers should be aware that:

• Claims about treating acne, rosacea, or other skin conditions are high-risk unless the product is properly registered.

• Testimonials and imagery must not imply medical efficacy unless substantiated by robust clinical evidence.

• The ASA is watching — literally. Its Active Ad Monitoring system uses AI to flag potentially non-compliant ads across platforms.

 Compliance Tips for Retailers

• Avoid medical terminology unless your product is MHRA-registered and appropriately marked.

• Don’t rely on testimonials or user-generated content to make medicinal claims.

• Review before/after imagery to ensure it doesn’t imply medical efficacy.

• Use disclaimers carefully — they won’t save an ad that makes an unauthorised claim.

• Train marketing teams on the difference between cosmetic and medical claims.

Howard Kennedy helps its clients avoid and respond to ASA claims. If you're planning an advertising campaign or are concerned about a competitor's misleading claims, please contact a member of the Intellectual Property & Commercial team.