NEW YORK, Aug. 3, 2022 /PRNewswire/ -- The National Advertising Division (NAD) of BBB National Programs determined that certain claims made by WaterWipes regarding the type and purity of ingredients used in its infant cleansing wipes were supported in context. For example, NAD found claims that simply underscore the advertiser's claimed benefit of its wipes or distinguish the number of ingredients in it wipes as compared to other competitor's wipes were properly limited and not falsely disparaging. However, NAD found that other claims that expressly or impliedly convey that competing baby wipes with more ingredients are harmful or can "cause or exacerbate diaper rash" were unsupported and recommended that they be discontinued.

NAD also recommended that WaterWipes discontinue:

• Efficacy claims that were based on the results of its "Baby Skin Integrity Comparison Survey" (BaSICS Study), including that babies cleansed with WaterWipes have a lower incidence and shorter duration of diaper rash compared to babies cleansed with other leading brands;
• "New independent clinical study reveals use of WaterWipes reduces incidence and shortens duration of diaper dermatitis in premature babies"; and
• "95% of healthcare professionals said they recommend WaterWipes."

These claims were challenged by Proctor & Gamble Company, maker of competing cleansing wipes for infants.

In a case decision issued in March, NAD determined that the BaSICS Study, which was designed to compare three different brands of baby wipes using parental observations of the incidence of diaper rash in infants from birth to eight weeks of age, does not provide adequate substantiation for WaterWipes' broad superiority claims ("#1 wipe against the causes of diaper rash" and "#1 cleansing wipes helping against the cause of diaper rash") or the establishment claim ("clinically proven as the #1 wipe against the causes of diaper rash") at issue in that challenge. Those same claims were also at issue in this challenge.

In the March decision, NAD recommended that the challenged claims be discontinued given its concerns with the reliability of the BaSICS Study. In its advertiser's statement, the advertiser agreed to abide by NAD's recommendation and discontinue its "#1" and clinically proven claims.

In the present matter, NAD determined that the BaSICS Study also does not provide adequate substantiation for the remaining BaSICS Study claims at issue in this challenge, each of which convey that WaterWipes outperformed the other wipes included in the study with respect to the incidence and shorter duration of diaper rash. Therefore, NAD recommended that WaterWipes discontinue certain claims, including:

• "New clinical study highlights how different baby wipe products can impact skin integrity of infants."
• "Baby Skin Integrity Comparison Survey reveals babies cleansed with WaterWipes had a lower incidence and shorter duration of diaper rash compared to other leading brands."
• "The [BaSICS] study of 698 mothers, showed babies cleansed with WaterWipes (brand three in the study; with the fewest ingredients) are less likely to get moderate to severe nappy rash, and if they do, it lasts fewer days compared to other leading brands."
• "For each day of nappy rash experienced by the WaterWipes babies, the rash would have lasted approximately 50% longer had mothers used the other brands – 1.69 days with brand two (p<0.001) and 1.48 days with brand one (p=0.002)."

In support of its claim "New independent clinical study reveals use of WaterWipes reduces incidence and shortens duration of diaper dermatitis in premature babies," the advertiser relied on the results of the Rogers Study, which evaluated the skin care of NICU babies by testing the implementation of particular skin care guidelines, including the use of WaterWipes.

NAD determined that the challenged claim reasonably conveys that the WaterWipes product itself helps shorter the duration of diaper dermatitis – a message not supported by the Rogers Study. NAD noted that the central finding of the Rogers Study is with respect to the study's Perineal Skin Care Guidelines and not the causal effect of using WaterWipes. Therefore, NAD recommended that the claim be discontinued.

NAD determined that the claims that simply underscore the advertiser's claimed benefit of its product (i.e., only two ingredients and 99.9% purified water) or distinguish the number of ingredients in WaterWipes as compared to other products were properly limited and not falsely disparaging to competing products. Those claims include:

• "WaterWipes baby wipes do not contain any chemicals or preservatives like other wet wipes"
• Whereas other baby wipes contain up to 16 ingredients, WaterWipes baby wipes have just two: Water (99.9%) – specially purified to clean babies' skin. A drop of fruit extract (0.1%) – to condition the skin and protect its integrity."

NAD also determined the claim "We recommend that HCPs are aware of the ingredients contained in baby wipe products being used on the delicate skin of babies. Given the minimal ingredients and purity credentials of WaterWipes, they are an ideal choice" to be supported in the context presented on the advertiser's website.

Further, NAD found the advertiser's "world's purest baby wipes" claim to be supported in context, which defined the message reasonably conveyed, that WaterWipes are the "world's purest baby wipes" because they contain only "99.9% water and a drop of fruit extract."

In contrast, NAD determined that certain other claims that expressly or impliedly convey that competing baby wipe products with more ingredients are harmful or can "cause or exacerbate diaper rash" were unsupported and recommended that they be discontinued including the claims:

• "WaterWipes baby wipes . . . don't contain the ingredients that can cause or exacerbate diaper rash,"
• "Other wipes can have up to 16 different ingredients that can irritate skin and could potentially cause or irritate diaper rash, even if they are labeled natural' or 'sensitive.'"
• "With WaterWipes, you never have to worry about what you're putting on your baby's delicate, sensitive skin because we have just two ingredients,"
• "WaterWipes are 99.9% water, which actually makes a huge difference because you can hide a lot of additional ingredients in .9%."
• Visual depiction of the number of ingredients (i.e., 2) in WaterWipes in a blue-colored heart in contrast to the number of ingredients in competing products depicted in a red circle or stop sign-like shape.
• Visual images of WaterWipes and "other wipes," each depicted as one droplet of water that convey there is something "less pure" or possibly unsafe, or harmful about the "other wipes."

NAD recommended that the claim "95% of healthcare professionals said they recommend WaterWipes" be discontinued due to a concern that use of the term "healthcare professionals" could convey the message to consumers that some pediatricians were included in the survey (which was limited to health, obstetric, and neonatal nurses). NAD also noted that healthcare professionals could include nurses, physician's assistants, and others.

In its advertiser statement, WaterWipes stated that it "agrees to comply with NAD's recommendations" although it "respectfully disagrees with certain findings related to implied takeaways of some claims."

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.

BBB National Programs is where businesses turn to enhance consumer trust and consumers are heard. The non-profit organization creates a fairer playing field for businesses and a better experience for consumers through the development and delivery of effective third-party accountability and dispute resolution programs. Embracing its role as an independent organization since the restructuring of the Council of Better Business Bureaus in June 2019, BBB National Programs today oversees more than a dozen leading national industry self-regulation programs, and continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-directed marketing, and privacy. To learn more, visit bbbprograms.org.

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.  

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