Tag: CE

New York, NY – November 9, 2026 – In a challenge brought by The Procter & Gamble Company, BBB National Programs’ National Advertising Division determined that Unilever United States, Inc. supported the challenged express and implied claims that Dove Deep Moisture Body Wash moisturizes skin for 24 hours, nourishes skin, and provides “Deep Moisture.”

P&G challenged claims that Dove Deep Moisture Body Wash provides moisturizing benefits for 24 hours after use, including “Nourishes Deeply for 24-Hours,” “24HR renewing MicroMoisture,” and “round-the-clock deep moisture.” P&G also challenged claims that the product nourishes the driest skin, as well as the product name “Deep Moisture.”

The 24-Hour Claims

Unilever supported its 24-hour moisturization claims with a short-term moisturization study (STM Study) designed to measure skin hydration over 24 hours following a single wash with Dove Deep Moisture Body Wash. NAD found that Unilever’s STM Study is an appropriate study to measure moisture on the skin. P&G submitted studies challenging the STM Study, but NAD concluded that P&G had not shown Unilever’s STM Study was flawed or that its own studies were more reliable. NAD therefore found Unilever’s evidence sufficient to support its claims that Dove Deep Moisture Body Wash moisturizes skin for 24 hours and provides continued moisture renewal and regeneration.

The “Round-the-Clock” Claim

P&G also challenged the “round-the-clock deep moisture” claim, arguing that it conveys significant moisturizing benefits for an extended period after in-shower use. NAD found that, because the claim appears above language stating that the product “restores moisture for 24 hours,” consumers could reasonably understand it to promise 24-hour moisturization. Having found the 24-hour claims supported, NAD determined that the round-the-clock claim was also supported.

The Nourishes Claim

P&G challenged the claim that Dove Deep Moisture Body Wash “NOURISHES THE DRIEST SKIN” and “actively regenerates skin’s natural moisture.” Unilever cited deposition studies showing that the body wash deposits fatty acids on and within the skin’s outer layer, helping restore lipids that support the skin barrier and moisture retention.

NAD found that consumers would understand “nourishes,” in the context of the surrounding claims about dry, soft, and hydrated skin, to mean that the product moisturizes. Because Unilever substantiated its moisturization claims, NAD found the “nourishes” claim supported.

The Product Name

P&G challenged the product name “Deep Moisture” falsely implies a moisturizing benefit, while Unilever maintained that the phrase could have multiple meanings and should not require a name change absent evidence of consumer confusion or deception.

NAD explained that a product name generally will not be required to change without extrinsic evidence of consumer confusion or deception, unless the name expressly conveys a false message. NAD determined that “Deep Moisture” expressly communicates that the product provides a moisturization benefit. As Unilever’s STM Study provided sufficient evidence that the product moisturizes skin, NAD found the product name supported.

In its advertiser statement, Unilever stated they are “pleased that NAD found all of the challenged claims that appear in advertising for Dove Deep Moisture Body Wash to be substantiated.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

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 20 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 fair competition 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 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 creating fair competition for business.

New York, NY – November 6, 2026 – Following a compliance inquiry stemming from a prior decision, BBB National Programs’ National Advertising Division will refer Kendal Nutricare Limited to appropriate government and state agencies and advertising platforms for review and possible enforcement action after the company elected not to participate in the compliance inquiry.

The referral follows a challenge brought by Abbott Laboratories concerning Kendamil Infant Formula advertising. In the underlying case (Case #7562), the National Advertising Division (NAD) recommended that Kendal discontinue or modify certain claims regarding whole milk, breast milk, human milk oligosaccharides (HMOs), milk fat content, and the brand’s heritage. Kendal agreed to comply with NAD’s recommendations and voluntarily discontinued an additional claim regarding its use of whole milk.

Abbott contacted NAD with concerns about nearly all of the challenged claims addressed in the original case. Kendal informed NAD that it elected not to participate in the compliance inquiry.

Accordingly, pursuant to the NAD/NARB Procedures, NAD will refer the matter to appropriate government and state agencies and to the platforms on which Kendamil’s advertising appears and with which NAD has a reporting relationship.

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

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 20 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 fair competition 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 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 creating fair competition for business.

New York, NY – November 4, 2026 – In a challenge brought by Eli Lilly and Company, BBB National Programs’ National Advertising Division recommended that Good Life Meds, LLC discontinue the challenged express health benefit and personalization claims for its compounded Tirzepatide+ products and modify its advertising to avoid conveying unsupported implied claims about product safety, efficacy, weight loss results, and personalization.

Good Life operates an online telehealth platform connecting consumers with healthcare professionals and pharmacies and markets prescription weight loss medications, including compounded tirzepatide products marketed as “Tirzepatide+.” Eli Lilly manufactures Mounjaro^® and Zepbound^®, the only tirzepatide-based medications approved by the U.S. Food and Drug Administration for Type 2 diabetes and chronic weight management, respectively.

Lilly challenged claims made by Good Life regarding the efficacy, safety, FDA status, and personalization of these compounded products.

Health Benefit Claims

The challenged health benefit claims related to the ability of compounded tirzepatide or Good Life’s Tirzepatide+ product to support healthy weight loss, provide natural energy boosts, and improve blood sugar control, all while preserving lean muscle mass.

NAD determined that the challenged claims, considered in the context of the advertising as a whole, reasonably convey the message that Good Life’s Tirzepatide+ as a finished compounded product (as opposed to any individual ingredient) supports weight loss, boosts energy, improves blood sugar control, and preserves lean muscle.

Although Good Life submitted substantial clinical literature on tirzepatide, separate literature on the additive ingredients, and real-world evidence including a Gallup survey and retrospective cohort studies, NAD found that this evidence was not a good fit for the claims. The tirzepatide literature largely concerned Lilly’s FDA-approved products, the record did not bridge the gap from the ingredient-level evidence to Tirzepatide+ as compounded, and the Gallup survey and cohort studies did not examine Tirzepatide+. The record contained no evidence evaluating the safety of combining tirzepatide with the additives, and the FDA’s decision to permit compounding during drug shortages did not substantiate the claims.

Accordingly, NAD determined that Good Life lacked a reasonable basis for the challenged express health benefit claims and recommended they be discontinued. NAD determined that the challenged implied claims are reasonably conveyed by the express health benefit claims and recommended that Good Life modify its advertising to avoid conveying the unsupported implied claims that Tirzepatide+ is safe and effective for these benefits and offers significant efficacy and weight loss results.

Personalization Claims

Lilly also challenged Good Life’s claims that Tirzepatide+ is a “personalized medication… tailored to meet individual patient needs” and “compounded for your unique needs.”

NAD determined that Good Life’s advertising conveyed a message of individualization that overstated what the underlying process involves. Although a prescribing physician may select among available formulations and dosage options and adjust a patient’s treatment plan over time, NAD determined that this does not mean the product itself is individually created or formulated for that patient.

Accordingly, NAD recommended that Good Life discontinue the challenged claims that Tirzepatide+ is “personalized,” “custom formulated,” “tailored to meet individual patient needs,” and “compounded for your unique needs.”

During the inquiry, Good Life voluntarily and permanently discontinued certain express and implied claims, including claims concerning the clinical results, benefits, ingredients, safety, and sourcing of its compounded tirzepatide products. NAD will treat the discontinued claims, for compliance purposes, as though NAD recommended the claims be discontinued.

In its advertiser statement, Good Life stated that though it “disagrees with many aspects of NAD’s decision,” it “will comply with NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

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 20 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 fair competition 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 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 creating fair competition for business.

New York, NY – October 30, 2026 – Following a challenge by The Procter & Gamble Company (P&G), BBB National Programs’ National Advertising Division determined that Clutch, Inc. d/b/a Carpe provided a reasonable basis for the $19.95 reference price used in its Underarm Stick savings claims, but recommended that Carpe modify or discontinue other challenged advertising, including savings, free shipping, comparative performance, and “first” 100-hour sweat and odor control claims.

Carpe markets personal care products, including its Underarm Stick, a deodorant and antiperspirant. P&G, which markets competing products, challenged claims made by Carpe on its website and social media for its Underarm Stick.

Pricing and Savings Claims

Carpe advertises savings on its Underarm Stick through recurring sitewide percentage-off promotions and offers that include free gifts. P&G challenged Carpe’s savings claims that were based on a $19.95 reference price that P&G asserted was not a bona fide regular price. The National Advertising Division (NAD) determined that Carpe provided a reasonable basis to support the $19.95 reference price used in its savings claims.

To obtain the represented percentage-off savings in the challenged advertising, consumers must enroll in a subscription program, with the level of savings dependent on the subscription tier and number of sticks purchased. NAD found that Carpe did not clearly and conspicuously disclose the subscription requirement for any challenged savings claims and recommended that Carpe discontinue those claims or clearly and conspicuously disclose, in close proximity to any price or savings claim that depends on subscription enrollment, that the offer requires an automatically renewing subscription, and also clearly and conspicuously disclose the recurring price and shipment frequency.

P&G also challenged certain Carpe sitewide percentage discounts delivered through successive seasonal and special-offer promotions. NAD found that Carpe’s percentage-off claims combined with other seasonal or “Special Offer” language, including countdown timers or scarcity statements, conveyed the message that Carpe’s promotions and sales last for a limited period of time. NAD found the claim unsupported and recommended that Carpe discontinue or modify its advertising to avoid conveying the message that a promotion or sale is available for a limited, discrete period unless the advertised savings opportunity is genuinely limited.

Regarding advertised savings and gifts, NAD recommended that Carpe discontinue the challenged “Save Up To [x]% Off w/ 4 Free Gifts” claims or modify its advertising to clearly and conspicuously disclose, in close proximity to the claim, when the advertised percentage savings includes the value assigned to the gifts. NAD further recommended that Carpe discontinue its free gift valuations or clearly and conspicuously disclose genuine, substantiated values, and discontinue using the cost of shipping in its savings calculations if the initial shipment is otherwise free.

NAD also recommended that Carpe discontinue its “free shipping” claims or modify its advertising to clearly and conspicuously disclose, in close proximity to the claim, that free shipping applies only to the initial shipment.

Comparative Claims

P&G challenged three social media posts including express comparative performance claims and the implied message that competing products are ineffective and worthless.

NAD found that the advertising conveyed the implied message and that Carpe did not support the challenged express comparative claims. It recommended that Carpe discontinue the express claims and modify its advertising to avoid conveying the unsupported message that competing deodorants and antiperspirants are ineffective or worthless.

NAD further determined that Carpe did not provide a reasonable basis for the claim that it is “the first deodorant to have 100 hours of clinically tested sweat and odor control” under any reasonable interpretations of that claim and recommended that Carpe discontinue the claim.

During the proceeding, Carpe voluntarily agreed to permanently discontinue its “100% Money-Back Guarantee” claim. Based on that representation, NAD did not review this claim on the merits and this claim will be treated, for compliance purposes, as though NAD recommended the claim be discontinued. 

In its advertiser statement, Carpe stated it will “comply with NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

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 20 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 fair competition 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 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 creating fair competition for business.

New York, NY – October 30, 2026 – Following a challenge brought by GuruNanda, LLC, BBB National Programs’ National Advertising Division reviewed advertising claims made by Davids Health Sciences, Inc. for its Pulling Oil Oral Rinse, including claims regarding certain of the product’s oral health benefits and a claim that the product is “Proudly made in USA.”

GuruNanda and Davids compete in the oral care market. GuruNanda challenged express and implied claims made for Davids Pulling Oil Oral Rinse concerning the product’s oral health benefits and U.S. origin.

During the inquiry, Davids informed the National Advertising Division (NAD) that it had permanently discontinued all challenged claims except “Proudly made in USA,” which it modified to include the qualification “with domestic and imported materials.” Therefore, NAD did not review the discontinued claims on their merits and will treat them, for compliance purposes, as though NAD recommended they be discontinued and Davids agreed to comply.

Because GuruNanda did not object to the modified claim, NAD did not review the modified claim on its merits. NAD will treat the original, unqualified “Proudly made in USA” claim, for compliance purposes, as though NAD recommended its modification and Davids agreed to comply.

In its advertiser statement, Davids stated that it “agrees to comply with NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

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 20 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 fair competition 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 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 creating fair competition for business.

New York, NY – October 22, 2026 – Following a reopened inquiry, BBB National Programs’ National Advertising Division recommended that Oral Essentials, Inc. (OEI) discontinue its “30 minutes to whiter teeth” claim for Lumineux Whitening Strips.

In the underlying challenge brought by the Procter & Gamble Company (P&G) (Case #7235), the National Advertising Division (NAD) determined that OEI provided a reasonable basis for its on-pack claim that Lumineux Whitening Strips “whitens without the sensitivity,” but recommended that OEI discontinue the claim “30 minutes to whiter teeth” or modify it to avoid conveying the message that consumers will experience whiter teeth after using the Lumineux product once for 30 minutes.

OEI discontinued the “30 minutes to whiter teeth” claim. In December 2025, OEI petitioned to reopen the proceeding and provided three new studies to support its claim. NAD determined that two of the studies were fatally flawed because they did not include a negative control, making it impossible for NAD to determine whether the whitening could be attributed to the Lumineux product or another variable.

Although the third study was randomized, double-blinded, and placebo-controlled, NAD determined that data discrepancies called its reliability into question. NAD found that the study included tooth color measurements that should have been impossible and unusually high standard deviations. NAD therefore concluded that the PWS Study was also fatally flawed.

Accordingly, NAD recommended that Oral Essentials continue to discontinue the claim “30 minutes to whiter teeth.”

In its advertiser statement, Oral Essentials stated that its advertising “will comply with NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

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 20 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 fair competition 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 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 creating fair competition for business.

McLean, VA – October 21, 2026 – As part of its routine, ongoing monitoring program, BBB National Programs’ National Advertising Division recommended that Virgin Cruises Intermediate Limited Inc. modify its Virgin Voyages advertising to clearly and conspicuously disclose service gratuities throughout the checkout process.

Virgin Voyages is an adults-only cruise line. At issue for the National Advertising Division (NAD) was whether Virgin Cruises highlighted a lead price without prominently disclosing the additional, mandatory per-night service gratuity, and whether the overall net impression of Virgin Cruises’ advertising may mislead consumers about the true all-in vacation cost.

NAD examined Virgin’s checkout process and determined that consumers are not sufficiently apprised about the discretionary nature of gratuities, how they are applied, and how they can remove them if they pay onboard. Additionally, the gratuities are referenced as a “service charge” in the final step of checkout which creates further confusion about whether they are optional.

Therefore, NAD recommended that Virgin Cruises modify its booking flow to clearly and conspicuously disclose throughout the checkout process that: (1) gratuities, while not mandatory, are not refundable if pre-paid; (2) the gratuities are higher if paid onboard; and, (3) if not prepaid, the consumer can modify or remove the gratuities prior to disembarkation including whether the removal of the gratuities are subject to the discretion of Virgin Cruises.

In its advertiser statement, Virgin Cruises Intermediate Limited stated it “appreciates the engagement” with the National Advertising Division on this matter and that it “agrees to comply with NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes. 

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 20 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 fair competition 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 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 creating fair competition for business.

McLean, VA – October 21, 2026 – As part of its routine, ongoing monitoring program, BBB National Programs’ National Advertising Division determined that Royal Caribbean Group’s voluntarily modified advertising is supported but recommended further changes to the company’s disclosures regarding optional pre-payment of gratuities to avoid potential consumer confusion.

Royal Caribbean is a cruise line operating since 1969 with over 30 ships to over 200 destinations for trips of varying durations. At issue for the National Advertising Division (NAD) was whether Royal Caribbean’s advertising disclosed all mandatory fees and whether the overall net impression of Royal Caribbean’s advertising was misleading about the true all-in vacation cost.

During the inquiry, Royal Caribbean modified its online booking flow to clearly and conspicuously disclose that gratuities are optional, that customers may choose whether to prepay them, and that they may modify or remove gratuities at any time prior to disembarkation.

Therefore, NAD determined that Royal Caribbean’s booking flow adequately apprised consumers of the true all-in vacation cost by highlighting the lead price and prominently disclosing that gratuities are not mandatory but, rather, are optional. However, to avoid potential consumer confusion, NAD recommended that Royal Caribbean modify the gratuities information in the “learn more” tab to clearly and conspicuously disclose that gratuities are optional, and to clearly and conspicuously disclose that gratuities are optional on the final checkout page.

In its advertiser statement, Royal Caribbean “thanks NAD for its careful review” and “has implemented NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

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 20 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 fair competition 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 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 creating fair competition for business.

McLean, VA – October 21, 2026 – As part of its routine, ongoing monitoring program, BBB National Programs’ National Advertising Division determined that Royal Caribbean Group’s voluntarily modified advertising is supported but recommended further changes to the company’s disclosures regarding optional pre-payment of gratuities to avoid potential consumer confusion.

Royal Caribbean is a cruise line operating since 1969 with over 30 ships to over 200 destinations for trips of varying durations. At issue for the National Advertising Division (NAD) was whether Royal Caribbean’s advertising disclosed all mandatory fees and whether the overall net impression of Royal Caribbean’s advertising was misleading about the true all-in vacation cost.

During the inquiry, Royal Caribbean modified its online booking flow to clearly and conspicuously disclose that gratuities are optional, that customers may choose whether to prepay them, and that they may modify or remove gratuities at any time prior to disembarkation.

Therefore, NAD determined that Royal Caribbean’s booking flow adequately apprised consumers of the true all-in vacation cost by highlighting the lead price and prominently disclosing that gratuities are not mandatory but, rather, are optional. However, to avoid potential consumer confusion, NAD recommended that Royal Caribbean modify the gratuities information in the “learn more” tab to clearly and conspicuously disclose that gratuities are optional, and to clearly and conspicuously disclose that gratuities are optional on the final checkout page.

In its advertiser statement, Royal Caribbean “thanks NAD for its careful review” and “has implemented NAD’s recommendations.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.

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 20 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 fair competition 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 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 creating fair competition for business.

McLean, VA – October 20, 2026 – BBB National Programs’ Digital Advertising Accountability Program (DAAP) has worked with Fast Retailing Co., Ltd. and four of its brands to bring their websites and mobile applications into compliance with the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for online interest-based advertising (IBA).

Fast Retailing Co., Ltd. is a global apparel retailer that operates UNIQLO, G.U. CO. LTD. (GU), Theory, and Helmut Lang.

As part of its routine monitoring, DAAP reviewed the online properties of UNIQLO and GU and observed data collection by third-party companies known to engage in IBA. DAAP identified potential issues concerning whether the websites and mobile applications provided consumers with the transparency and choice mechanisms required by the DAA Principles.

DAAP subsequently expanded its review to the websites of Fast Retailing’s Theory and Helmut Lang brands, and the mobile applications operated by UNIQLO, GU, and Theory.

The review found that the UNIQLO, GU, Theory, and Helmut Lang websites did not provide consumers with appropriate enhanced notice for IBA, that is, a clear and prominent link to information explaining data sharing for IBA and a mechanism to opt-out of such sharing. While privacy policies contained much of the information required under the DAA Principles, the information was scattered throughout the policies rather than presented in a clearly identified IBA disclosure. As a result, consumers may have had difficulty finding information about IBA and mechanisms available to exercise choice with respect to IBA.

DAAP also found that the UNIQLO, GU, and Theory mobile applications did not provide appropriate enhanced notice under the DAA’s Mobile Guidance. The apps did not provide clear and prominent access to IBA disclosures and choice mechanisms at the times and places contemplated by the Mobile Guidance, including through app settings. The apps’ use of an infinite scroll format also prevented users from readily reaching disclosures and opt-out links to privacy information located at the bottom of the screen.

In response to DAAP’s inquiry, Fast Retailing worked with DAAP to review the websites and mobile applications of all four brands and implemented a range of changes to strengthen transparency and consumer choice.

Enhanced Notice of Website Data Collection for IBA

To comply with the DAA Principles’ enhanced notice requirements, UNIQLO, GU, Theory, and Helmut Lang:

• Added an “Ad Choices” link to their website footers that is separate and distinct from each brand’s general privacy policy link and appears on every page of the website.
• Directed the “Ad Choices” link to the IBA section of each brand’s privacy policy to provide consumers with direct access to information about IBA and available choice mechanisms.
• Consolidated IBA-related information into a dedicated “Ad Choices” section of each brand’s privacy policy.

The updated “Ad Choices” sections explain IBA, include a statement of adherence to the DAA Principles, provide a functioning link to an industry-developed consumer choice mechanism, and explain how consumers can withdraw consent.

At DAAP’s recommendation, UNIQLO and GU also added a link at the top of their privacy policies directing consumers to the “Ad Choices” section.

Enhanced Notice for Third-Party Interest-Based Advertising

To comply with the DAA Mobile Guidance, UNIQLO and GU implemented changes to provide consumers with clearer and more prominent notice of cross-app data collection for IBA, including:

• Adding a link to an IBA disclosure and DAA consumer choice tools at the top of their mobile privacy policies.
• Eliminating the infinite scroll feature that had prevented users from readily reaching menu and footer links, including links to privacy information.
• Adding “Ad Choices” to their in-app settings, giving users ongoing access to IBA disclosures and choice mechanisms after downloading the apps.
• Adding links within their IBA disclosures to the DAA’s consumer choice tools, including Ad Choices.
• Updating their iOS and Android app store listings with privacy policy links directing users to the top of their Privacy Notices, where consumers can more easily access the IBA disclosures.

Theory eliminated the infinite scroll feature from its app, added “Ad Choices” to its in-app settings, and added a link to the DAA’s consumer choice tools in its mobile privacy policy.

Helmut Lang does not offer a mobile application.

All BBB National Programs case decision summaries can be found in the case decision library. To access all DAAP decisions, visit the DAAP decisions webpage.  

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 20 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 fair competition 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 Digital Advertising Accountability Program: The Digital Advertising Accountability Program (DAAP), a division of BBB National Programs, was developed by the Digital Advertising Alliance (DAA) to enforce industry self-regulation principles for data privacy in online and mobile advertising, holding companies accountable to the DAA’s Privacy Principles. DAAP provides guidance to companies looking to comply with industry principles and responds to complaints filed by consumers about online privacy.