Adverting watchdog draws the line at misleading Botox promotion

Companies fall foul of advertising rules for ‘misleading’ posts on Facebook and Instagram

Complaints against two companies concerning anti-wrinkle treatment have been upheld by the Advertising Standards Authority of Ireland. File photograph: Getty Images

The Advertising Standards Authority of Ireland (ASAI) upheld five complaints against advertisers according to its latest quarterly bulletin.

In one complaint upheld by the authority, posts on the Facebook page of the Eden Medical Group were deemed to be misleading.

The page featured before and after anti-wrinkle treatment photographs.

The complainant noted the posts in question to be misleading. She said it was her opinion that the before treatment photographs had featured the client with scrunched up features to make it appear that post treatment, when the client appeared with a relaxed expression, that all the lines and crevices had disappeared as a result of having the anti-wrinkle treatment.


A similar complaint was upheld against the Sisu Aesthetic Clinic in Cork, which had posted photographs to Instagram that the complainant deemed misleading.

The post was accompanied by before and after treatment photographs of the Client. It read : “You saw in yesterday’s video how delighted . . . is with her anti-wrinkle injections and Botox from Sisu. Why not treat yourself to a bit of transformation too? Call . . . to make your appointment.”

In the before-treatment picture the client’s forehead was set in a frown. In the second after-treatment image the client’s forehead was set in a relaxed pose.

The complainant said the “before” treatment photographs had a model’s face scrunched up and frowning to emphasise her wrinkles, while in the after anti-wrinkle treatment photographs her face appeared to be far more relaxed.

The ASAI committee considered use of the before photographs in this case did not depict normal appearance of the wrinkles. They were, therefore, likely to mislead as to the actual impact of the treatment on the appearance of the wrinkles.

There were two complaints against Hidden Hearing. In one, the complainant claimed on hearing an advertisement he rang to get an appointment as one of 25 volunteers to test the new hearing equipment. But when he went for his appointment, he was not provided with new equipment to test as indicated. Instead he said he was given a “hard sell” for a hearing aid which cost €4,700.

A second complainant applied to be one of the volunteers for the trial after getting a text from the company. He was told that in order to take part in the trial he would have to purchase a hearing aid up front.

There was also a complaint partly upheld against the Irish Greyhound Board over an advertisement that referenced gambling, but which the complainant said had not included any reference to responsible gambling. The ASAI ruled the radio advert must not reappear in its current form as it should include a responsibility message.

The advertising watchdog did not uphold a complaint against EBS which questioned whether it had been in existence since 1935 as it claimed in an advertisement. The advertisements read: “EBS have being bringing mortgages home since 1935, that’s what makes them the ‘Mortgage Masters’ ”.

The complainant said the building society ceased to exist on July 1st, 2011. After being granted a banking licence, and demutualising, they became EBS Limited, a subsidiary of AIB.

In September 2016, EBS Limited re-registered as a designated activity company as required under the Companies Act.

The committee concluded that the advertising was unlikely to materially mislead consumers and did not uphold the complaint.