NAD takes issue with Charmin toilet tissue

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The National Advertising Division (NAD) of the Council of Better Business Bureaus has recommended that Procter & Gamble modify certain ad claims made Charmin Ultra Strong bath tissue. NAD determined that the advertiser can support certain claims. NAD, the advertising industry’s self-regulatory forum, examined broadcast and Internet advertising for the product following a challenge by Kimberly-Clark Global Sales, LLC, maker of Cottonelle Ultra.


Claim at issue included:
* Charmin Ultra Strong “leaves fewer pieces behind than the Ultra Ripple Brand [Cottonelle Ultra].”
*  “Charmin Ultra Strong holds up better [than the Ultra Ripple Brand] … with fewer pieces left behind than the Ultra Ripple Brand”

Following its review of the evidence, which included wet tensile strength testing, NAD determined that the advertiser’s evidence, although imperfect, provided a reasonable basis for the claim that Charmin Ultra Strong “Holds Up Better.”

In support of the claim that Charmin Ultra Strong “leaves fewer pieces behind” than Cottonelle Ultra, the advertiser relied upon rub testing, during which dry tissue was rubbed across black felt, and consumer-use testing. NAD determined that the advertiser provided a reasonable basis for the claims Charmin Ultra Strong left “fewer pieces behind” than Cottonelle Ultra.

NAD next addressed the challenged product demonstrations, offered in an online video and in broadcast advertising, to convey the claim Charmin Ultra Strong left “fewer pieces behind” than Cottonelle Ultra.

In the online demonstration, stacks of Charmin Ultra Strong and Cottonelle Ultra Ripple are moistened, placed under weights on a felt surface, and then dragged along the surface via a mechanical device. The Ultra Ripple Brand left behind large, visible pieces of toilet paper, in contrast to Charmin Ultra Strong which appeared to leave no pieces behind.

NAD determined that the demonstration overstated the extent of product superiority and did not accurately reflect the results that consumers typically see and experience. As such, NAD recommended that the demonstration be discontinued.

NAD also observed that in the advertiser’s commercials, which feature animated bears, a bear has numerous pieces of toilet paper left behind prior to using the advertised product, but is toilet paperfree after using the product.

Although a voiceover states that Charmin Ultra Strong leaves “fewer” pieces behind, NAD determined that the language is directly contradicted by the visuals, which depict no pieces left behind. NAD recommended that the advertiser avoid in future advertising depictions or language that convey the message that Charmin Ultra Strong leaves no pieces behind.

Procter & Gamble responded and said it is “disappointed that NAD found that the
product demonstration overstates the substantial difference between the two products, and that the demonstration, along with the animation depicting the before and after bears hindquarters, delivers an absolute message of ‘no pieces left behind.’”

Nevertheless, P&G said it “agrees to comply with NAD’s recommendation to discontinue the challenged demonstration and to modify future advertising consistent with this decision.”

NAD’s inquiry was conducted under NAD/CARU/NARB Procedures for the Voluntary Self-Regulation of National Advertising.

The National Advertising Review Council (NARC) was formed in 1971. NARC establishes the policies and procedures for the National Advertising Division (NAD) of the Council of Better Business Bureaus, the CBBB’s Children’s Advertising Review Unit (CARU), the National Advertising Review Board (NARB) and the Electronic Retailing Self-Regulation Program (ERSP).

RBR-TVBR observation: Indeed, we’ve all seen the commercials and probably don’t concern ourselves with “pieces left behind.” Nonetheless, when advertisers make claims that directly challenge their competition, they had better be correct in their claims. If not, there are non-legal remedies available, as demonstrated here, that may save both parties a lot of legal fees.


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Carl has been with RBR-TVBR since 1997 and is currently Managing Director/Senior Editor. Residing in Northern Virginia, he covers the business of broadcasting, advertising, programming, new media and engineering. He’s also done a great deal of interviews for the company and handles our ever-growing stable of bylined columnists.