New York, NY – October 31, 2023 – In a challenge brought by Bath & Body Works, LLC (B&BW), the National Advertising Division (NAD) of BBB National Programs determined that the tagline “Bath, Body & Home” was not misleading, but recommended that Goose Creek Candles, LLC:
NAD found that one message reasonably conveyed by Goose Creek’s “avoid the harmful chemicals found in other body care products” claim is that other competitive body care products contain harmful chemicals. NAD determined that the record did not support this claim and recommended that it be discontinued, as well as implied claims that competitors’ products contain harmful chemicals.
NAD determined that the advertising at issue conveys the message that Goose Creek candles last longer and have a stronger fragrance than competitors. NAD found insufficient evidence to support these superiority claims and recommended the following fragrance claims by Goose Creek be discontinued:
NAD also recommended that Goose Creek discontinue any advertising that implies that Goose Creek candles are stronger or longer lasting than competing candles.
Made in U.S.A. Claims
NAD recommended that Goose Creek modify its “Made in USA” claims (“poured in the USA with the highest ingredients from around the world”) to be consistent with FTC guidance and limit claims to the processes or candle ingredients that are made in the USA.
NAD determined that several videos across Goose Creek’s online platforms convey the message that people featured are actually consumers, not actors, who are giving their opinions. NAD recommended that any Goose Creek content featuring actors portraying consumers be modified to clearly and conspicuously disclose, in both audio and video, that actors have been employed in the videos.
Further, NAD reviewed videos posted by a candle vlogger @TheCandleChannel, who became a label designer for Goose Creek Candles in July 2023. NAD determined that Goose Creek’s relationship with @TheCandleChannel vlogger is a connection that would likely affect the weight or credibility of the endorsements and is a material connection that must be clearly and conspicuously disclosed.
For this reason, NAD recommended that Goose Creek require @TheCandleChannel to modify any video created after the date of employment with Goose Creek to include a clear and conspicuous material connection disclosure.
B&BW challenged consumer reviews that appear on Goose Creek’s website as well as 5-star video reviews. NAD found there was no evidence that Goose Creek’s review collection process persuades consumers to leave only positive reviews and determined that Goose Creek’s review collection process incentivizes both positive and negative reviews.
However, because Goose Creek’s incentivized consumer reviews are not disclosed, NAD recommended that all consumer reviews posted or re-posted by Goose Creek be modified to include a clear and conspicuous disclosure that the review was incentivized.
NAD determined that the tagline “Bath, Body & Home” does not convey a misleading message that equates Goose Creek products with B&BW products.
In its advertiser statement, Goose Creek stated that “while Goose Creek believes that its advertising verbiage and methods have truthfully conveyed the many benefits of its products, it appreciates the NAD’s thorough review and guidance” and “agrees to comply with the NAD’s recommendations regarding its advertising.”
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About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.
About the National Advertising Division: The National Advertising Division (NAD) of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. NAD reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.
Name: Jennie Rosenberg
Job Title: Media Relations