NAD Tells PrettyBoy Skincare to Tighten or Drop Claims After Review of Yuka Score, Star Ratings and Before-and-After Photos

Table of Contents

  1. Key Highlights:
  2. Introduction
  3. What NAD found in the PrettyBoy review
  4. Why Yuka scores matter — and what advertisers must disclose
  5. Before-and-after photographs: when images become measurable claims
  6. Seals, badges and third-party endorsements: what they do—and their limits
  7. Evidence standards: what “competent and reliable scientific evidence” looks like for skincare
  8. How to display user ratings and star scores without risking misrepresentation
  9. Building a compliance-first creative process for skincare marketing
  10. The broader marketplace impact: men's skincare, trust and regulatory expectations
  11. NAD’s role, authority and next steps for advertisers
  12. Practical checklist: How skincare brands should approach claims, images and badges
  13. Real-world application: what a compliant before-and-after claim might look like
  14. Why brands should welcome this scrutiny
  15. Looking ahead: practical questions advertisers should ask now
  16. FAQ

Key Highlights:

  • The National Advertising Division recommended PrettyBoy modify or discontinue claims tied to a Yuka app “100/100” health score, third-party star ratings, and before-and-after photographs showing eczema and aging improvements.
  • NAD found the advertising lacked adequate disclosure about the basis for the Yuka ranking, that image-based performance claims require competent scientific support, and that reliance on a third-party seal alone did not substantiate medical or therapeutic depictions.
  • PrettyBoy removed a “Trusted by 20,000 Men (5-star rating)” claim during the inquiry and said it will comply with NAD’s recommendations; the case highlights compliance steps skincare brands must take when using app scores, seals and consumer-facing imagery.

Introduction

A recent decision from the National Advertising Division (NAD) tightened scrutiny on how skincare brands present third-party ratings, badges and visual proof of product performance. NAD reviewed advertising for PrettyBoy Skincare, a men-focused brand, and recommended changes to claims tied to a high health rating displayed from the Yuka mobile app, certain star-rating claims, and before-and-after photographs that depict reductions in eczema-related redness and signs of aging. The ruling underscores the regulatory expectation that consumer-facing claims—whether based on app scores, seals of acceptance, or photographs—must be transparent, substantiated and not misleading.

The advisory has implications beyond one small brand. Marketers now face a clearer signal about how third-party endorsements and clinical-looking images should be presented. The decision also illustrates how independent self-regulatory bodies operate to protect consumers and ensure fair competition among advertisers. The outcome for PrettyBoy—removal of an inflated five-star claim and a commitment to comply—offers a practical roadmap for other consumer brands that rely on app badges, seals, or dramatic photographic demonstrations of effectiveness.

What NAD found in the PrettyBoy review

NAD opened an inquiry into advertising for PrettyBoy Skincare after identifying three categories of concern: a prominently displayed Yuka health score, before-and-after photographs purporting clinical or materially meaningful improvement, and star ratings tied to consumer counts. NAD evaluated whether these representations made the basis of the claims sufficiently clear and whether the advertiser had support commensurate with the impressions conveyed.

  • Yuka app score: PrettyBoy displayed a “100/100 Health Score (via the Yuka App)” for its Revival Recovery Gel Moisturizer. NAD concluded that the brand’s page did not adequately explain how the score was calculated or what the score actually signified. The Yuka score was driven by ingredient-level assessments—absence of certain ingredients such as parabens or specific UV filters—rather than measured clinical outcomes on users. NAD recommended PrettyBoy modify advertising to clarify the basis of the ranking.
  • Before-and-after photographs: The images used in PrettyBoy’s advertising showed reductions in eczema-related redness and improvements in fine lines and under-eye bags. NAD treated those images as express product-performance claims and required competent and reliable scientific evidence to support the depicted results. The advertiser’s reliance on the National Eczema Association (NEA) Seal of Acceptance for two products, without underlying clinical testing tied to the photographs, fell short of the evidentiary standard. NAD recommended discontinuation of the before-and-after photos.
  • Star-rating and “Trusted by” claims: During the inquiry PrettyBoy voluntarily discontinued a claim that it was “Trusted by 20,000 Men (5-star rating).” Because the advertiser removed that claim, NAD did not rule on its merits but noted the discontinuation would be treated as compliance.

PrettyBoy issued a statement acknowledging the review and indicating it would comply with NAD’s recommendations. The decision and the advertiser’s response highlight the practical consequences for brands that rely on third-party badges and imagery to convey efficacy.

Why Yuka scores matter — and what advertisers must disclose

Yuka is a consumer-facing mobile application that scans product ingredient labels and assigns a numerical score intended to reflect ingredient safety and, in some versions of the app, ecological impact. The score reflects an independent ingredient-level assessment rather than direct measurement of clinical outcomes such as reduced redness or diminished wrinkles.

Advertisers often display an app-derived score because it appears authoritative and easy for consumers to interpret. But a high number on a third-party app is not self-explanatory. Without context, a “100/100” badge implies ultimate endorsement of product safety or healthfulness and can be interpreted by consumers as an absolute guarantee of benign effects. NAD’s determination focused on the need for clarity: if a score is based strictly on ingredient absence rather than user outcomes, advertising must make that distinction plain.

What NAD’s recommendation requires in practice:

  • State the basis of the score near the badge. If an app bases the rating on ingredient analysis, the advertiser should indicate that the rating reflects an ingredient-safety assessment rather than clinical efficacy or consumer satisfaction.
  • Avoid implying that the app rating represents comprehensive testing, clinical efficacy, or official regulatory approval unless the app actually provides and documents those evaluations.
  • If the rating is time-bound or based on specific versions of a formula, disclose that the score applies to the ingredients listed at a specific date.

A real-world parallel: nutritional front-of-pack labels or “clean-label” claims also require disclosure of methodology when they might reasonably mislead. A product labeled as “non-toxic” or carrying a top-scored badge can mislead if the methodology behind the assessment is not described. Consumers interpret badges as endorsements; transparency helps align expectations with what was actually evaluated.

Before-and-after photographs: when images become measurable claims

Photographs are persuasive. A single before-and-after pair can convey dramatic improvement in skin texture, tone, or inflammation. NAD characterized PrettyBoy’s images as performance claims rather than mere testimonials or illustrative content. That classification triggers the need for competent and reliable scientific evidence to substantiate the images.

What constitutes adequate substantiation for before-and-after images:

  • Representative results: Images must reflect the typical or reasonable user experience, not cherry-picked, exceptional outcomes.
  • Controlled conditions: Photographs should be taken under standardized lighting, camera settings, positioning and without makeup, filters, or digital manipulation. Images captured by independent clinical evaluators carry greater weight.
  • Objective endpoints: When a claim involves a medical condition (e.g., eczema), advertisers must rely on clinical evidence appropriate to the claim. The depiction of reduced eczema-related redness moves the image from a cosmetic improvement to a therapeutic claim, elevating the required standard of support.
  • Adequate study design: For images implying therapeutic or objectively measurable changes, randomized, controlled, and blinded trials—or at minimum, rigorously designed clinical studies with validated outcome measures—provide the strongest support.

NAD rejected PrettyBoy’s reliance on the NEA Seal alone as sufficient to support the specific visual claims. Seals can demonstrate that a product meets certain ingredient safety criteria or has been reviewed for tolerability, but they do not replace studies designed to measure improvement in a condition. The NEA Seal indicates the product is acceptable for use by people with eczema-prone skin based on ingredient criteria and dossier review, not proof that the product reduces eczema severity.

Photographic examples that comply:

  • A study shows 70% of participants experienced a quantifiable reduction in clinician-rated erythema after eight weeks. Those results are accompanied by standardized, time-stamped clinical photos taken with controlled lighting and evaluated by blinded dermatologists.
  • Consumer-submitted images used to illustrate typical outcomes are accompanied by clear text stating the images reflect individual user experiences and are not representative of all users.

Photographic examples that don’t comply:

  • A single dramatic image with no disclosure about timing, lighting, or whether results are typical.
  • Use of makeup, lighting tricks, or filters that materially alter appearance without disclosure.

Advertisers should assume any visual depiction of improvement invites demands for evidence; treating before-and-after photos as merely illustrative risks regulatory intervention.

Seals, badges and third-party endorsements: what they do—and their limits

Seals of acceptance and third-party badges carry governance weight for consumers but are not substitutes for evidence of performance. Organizations such as the National Eczema Association review ingredient lists and product dossiers and may grant seals indicating a product meets certain standards. That process helps consumers identify products formulated to minimize common irritants, allergens or potentially problematic ingredients. But NAD’s determination draws a line between a seal that addresses formulation safety and claims that a product therapeutically improves a condition.

Key distinctions advertisers must observe:

  • Seal of acceptance: Typically indicates the product’s ingredients and formulation are appropriate or acceptable for people with a given condition. It does not necessarily indicate clinical effectiveness.
  • Certification vs. endorsement: Some certifications stem from standardized testing and audits (e.g., safety testing for harmful contaminants), while other seals reflect screening against lists of ingredients of concern. Each has a different evidentiary burden.
  • Third-party app scores: Apps that evaluate ingredient lists use algorithmic frameworks and expert panels. The score can be informative but must be accompanied by clarity on the scoring methodology.

Practical guidance:

  • When using a seal, explain what the seal evaluates and what it does not. If the seal does not evaluate clinical efficacy, advertising should avoid language that implies otherwise.
  • When displaying third-party ratings, link directly to the methodology or provide a concise disclosure on the same page that summarizes how the score is calculated.
  • Avoid juxtaposing a safety-oriented badge with claims of performance that the badge does not support.

Real-world brands have faced scrutiny for implying that third-party badges conferred clinical endorsements. That scrutiny typically targets presentation, not the seal itself. Proper context mitigates risk.

Evidence standards: what “competent and reliable scientific evidence” looks like for skincare

NAD’s demand—that before-and-after images and objective claims be supported by competent and reliable scientific evidence—echoes long-standing advertising standards. The Federal Trade Commission’s substantiation policy and NAD precedent require evidence commensurate with the express or implied claim. For clinical or therapeutic assertions, that generally means well-designed clinical trials.

Elements of competent and reliable scientific evidence for skincare claims:

  • Study population: Participants should reflect the demographic and clinical profile represented in advertising. If a product claims benefit for adults with eczema, the study should enroll individuals diagnosed with eczema.
  • Endpoints: Use validated outcome measures such as standardized clinician-rated scales for erythema, transepidermal water loss for barrier function, or validated wrinkle-assessment scales for aging claims.
  • Controls and comparators: Randomized, placebo-controlled trials avoid confounding and placebo effects, particularly where subjective endpoints (appearance) are involved.
  • Blinding: Blinded assessments by independent raters reduce bias in photographic evaluation.
  • Sample size and statistical analysis: Studies should be powered to detect meaningful differences and report pre-specified analyses.
  • Reproducibility: Repeated studies or multi-center trials increase confidence in generalizability.

For less rigorous or cosmetic claims—e.g., “improves moisturization over 24 hours”—controlled instrumental measurements like corneometry or transepidermal water loss measurements may suffice. However, image-based claims of visible reductions in inflammation or structural wrinkles require higher standards.

When studies involve photography:

  • Document camera models, lenses, lighting and angles.
  • Use standard color references and scales to allow objective comparison.
  • Time-stamp and archive original raw image files.
  • Ensure post-processing is limited to neutral adjustments that do not alter visual outcomes; disclose any adjustments.

Advertisers should preserve study protocols, raw data, and photographic originals to verify claims if challenged. NAD and other bodies can request underlying documentation, and a failure to produce adequate records increases the risk of unfavorable rulings.

How to display user ratings and star scores without risking misrepresentation

Star ratings and “trusted by X users” statements can convey social proof. But those claims can mislead if based on small sample sizes, manipulated reviews, or if the methodology for computing the score is opaque.

Compliance practices for displaying star ratings:

  • Source clarity: Indicate whether the rating is aggregated from the brand’s website, a marketplace, or an independent review platform. If from a third-party app, link to the source.
  • Timeframe and sample size: If claiming “20,000 users,” disclose whether that figure reflects purchasers, registered accounts, app scans or some other denominator. A simple parenthetical—e.g., “(based on 20,000 app scans in 2025)”—helps.
  • Avoid implying accuracy beyond the sample: If ratings come from a small or self-selected sample, avoid presenting them as representative.
  • Update claims as counts change: A static claim that reads as current when the underlying number has declined is misleading.
  • Prevent manipulation: Actively monitor for fake reviews and show steps taken to ensure integrity.

Case handling in PrettyBoy’s situation: The brand removed the “Trusted by 20,000 Men (5-star rating)” claim during the NAD inquiry. Removal suggests recognition of potential ambiguity or insufficient documentation. Brands that preemptively audit review sources and ensure transparent presentation reduce the risk of similar enforcement.

Building a compliance-first creative process for skincare marketing

Marketers should integrate legal and scientific review into creative development, particularly for skincare products that straddle cosmetic and therapeutic categories. The following process reduces downstream risk and protects brand credibility.

  1. Claim matrix: For each proposed claim (visual, textual or rating-based), document the claim’s exact wording, the medium where it will appear and the evidence supporting it.
  2. Evidence audit: Map each claim to the underlying evidence: clinical studies, instrumental measures, third-party reviews, seals and consumer testimonials. Note any gaps.
  3. Methodology transparency: For third-party badges or app scores, obtain and summarize the methodology. If the methodology is proprietary and unavailable, err on the side of caution when presenting an absolute badge or score.
  4. Photography protocol: Develop a standardized photo protocol for before-and-after imagery. Use the same camera, lighting and environment, and have photos taken by trained personnel or independent clinics.
  5. Legal review: Legal counsel should assess claims against advertising rules and self-regulatory standards, ensuring disclosures are sufficient and not buried.
  6. Periodic revalidation: Update studies, ratings and sample sizes periodically. Remove or revise claims if the underlying support no longer applies.
  7. Crisis plan: Prepare remediation steps for disputes, including rapid removal of problematic claims and immediate communication with regulators or self-regulatory bodies.

Embedding these checks early reduces the chance of NAD, FTC, or other regulators questioning a campaign after launch.

The broader marketplace impact: men's skincare, trust and regulatory expectations

Men’s skincare has experienced rapid growth and evolving positioning—products marketed specifically to men often borrow imagery and claim frameworks from mainstream skincare. NAD’s decision in the PrettyBoy case signals that targeted marketing does not loosen evidentiary expectations.

Three ecosystem effects to expect:

  • Higher scrutiny for images that suggest therapeutic benefits: As consumers become more skeptical, regulators will continue to treat images as potential performance claims unless clearly framed otherwise.
  • Caution around app-based badges: Apps like Yuka are prominent tools for ingredient-centric shoppers. Brands will need to ensure that badges are contextualized so consumers do not infer clinical efficacy from ingredient-safety evaluations.
  • Elevated expectations for transparency: Consumers expect more information about how ratings are derived. Brands that proactively explain methodologies and limitations earn credibility.

Reputational risk is not limited to regulatory outcomes. Social media amplification of a regulatory admonition can cause rapid reputational damage. Brands that adopt transparent practices and invest in robust substantiation may convert regulatory compliance into a trust advantage.

NAD’s role, authority and next steps for advertisers

NAD operates under BBB National Programs as an independent self-regulatory body for advertising. It reviews national advertising in all media and issues recommendations to advertisers to promote truth and accuracy. NAD rulings do not carry the force of law in the way a court judgment does, but they carry industry weight and can be referred to higher review bodies within the self-regulatory system, such as the National Advertising Review Board (NARB). Parties that decline to follow NAD’s recommendations can face public naming and potential referral to government agencies, including the FTC.

Key aspects of NAD proceedings:

  • Scope: NAD examines national advertising claims across media and industries.
  • Evidence review: NAD evaluates the sufficiency of evidence and may request documentation supporting claims.
  • Remedies: NAD typically recommends modification or discontinuation of claims; advertisers may comply, appeal to NARB, or risk escalation.
  • Publication: Decisions and summaries are published, creating precedents that guide future advertising conduct.

For PrettyBoy, the case concluded with the advertiser agreeing to comply. That pathway—voluntary compliance following review—is common. Where advertisers appeal, NARB provides further adjudication. Brands should view NAD engagement as both a corrective mechanism and an opportunity to align marketing with best practices.

Practical checklist: How skincare brands should approach claims, images and badges

Use this practical, step-by-step checklist to avoid the pitfalls highlighted by the PrettyBoy decision.

Before publishing:

  • Identify every claim (text, image, badge, star rating).
  • Confirm the basis for each claim—clinical study, instrumented measurement, ingredient assessment, third-party reviews, or consumer testimonials.
  • For third-party badges, obtain the scoring methodology and, where feasible, link to it or summarize it in advertising.
  • For star ratings or “trusted by” numbers, document the data source, date range and methodology for calculation.
  • For before-and-after photos, ensure standardized photographic protocols, time-stamped images, and accompanying study documentation where outcomes are objective.
  • If advertising relief from a medical condition (e.g., reduced eczema), secure clinical evidence appropriate to the claim; ingredient safety seals do not suffice.

During creative review:

  • Add concise, prominent disclosures where context is necessary.
  • Avoid absolute language unless supported by evidence (e.g., “clinically proven to reduce redness”).
  • Use representative images rather than exceptional results, and explicitly state when images depict individual outcomes if they are not typical.

After publishing:

  • Monitor consumer feedback and reviews to detect inaccurate or misleading impressions.
  • Update claims as evidence evolves or as product formulation changes.
  • Retain raw data, study reports, and photographic originals for at least several years.

When a challenge arises:

  • Respond promptly, including removal or revision of claims where appropriate.
  • Document remedial steps publicly to preserve consumer trust.
  • When appropriate, engage with self-regulatory bodies proactively to resolve disputes.

Real-world application: what a compliant before-and-after claim might look like

Imagine a moisturizer advertising “Reduces visible redness by 40% in 8 weeks (clinical study, n=120).” A compliant presentation would meet these criteria:

  • The ad cites the study design: randomized, controlled, evaluator-blinded.
  • The population is described (e.g., adults with mild-to-moderate eczema, age range).
  • The measurement tool for redness is identified (e.g., physician-assessed erythema score).
  • The result is tied to a specific timeframe (8 weeks) and sample size (n=120).
  • Representative before-and-after photos are taken under standardized conditions and accompanied by a disclosure that individual results vary.
  • The study protocol and final report are archived and available upon request.

Such clarity makes the claim verifiable and reduces the risk that the imagery will be treated as unsupported.

Why brands should welcome this scrutiny

Rigorous review of advertising claims raises the bar for all market participants. Brands that invest in robust substantiation protect themselves from regulatory scrutiny and build longer-term consumer trust. Well-substantiated claims withstand scrutiny and reduce the risk of costly campaign retractions, corrective advertising or reputational damage.

For newer brands, a proactive approach—commissioning adequate studies early and using transparent messaging—can become a competitive differentiator. Consumers confronted with clear, well-documented claims are more likely to trust and remain loyal to brands that demonstrate accountability. The PrettyBoy case shows that even smaller brands can face effective challenges; meeting the evidentiary standard eliminates that vulnerability.

Looking ahead: practical questions advertisers should ask now

  • Does any badge or score on our site imply more than it truly represents? If so, how can we clarify it?
  • Do our images imply typical outcomes or extreme results? Are they representative?
  • For claims that appear clinical or therapeutic, do we have clinical trials or equivalent evidence?
  • How often do we audit our third-party ratings and review the methodology behind them?
  • Do we have an evidence repository that legal and regulatory teams can access quickly?

Answering these questions conservatively reduces risk and aligns advertising with consumer expectations.

FAQ

Q: What prompted NAD to review PrettyBoy’s advertising? A: NAD reviewed PrettyBoy’s advertising after concerns arose over a displayed Yuka app “100/100” health score, before-and-after photographs showing reductions in eczema and signs of aging, and star-rating claims. NAD evaluated whether those representations adequately disclosed their basis and whether the advertiser had sufficient evidence to support them.

Q: What is the Yuka app score, and why was it a problem? A: Yuka assigns a score based on an ingredient-level analysis that assesses potential health and environmental concerns associated with listed ingredients. NAD found that PrettyBoy’s use of a “100/100” badge did not make clear that the score reflected ingredient assessment rather than measured clinical outcomes. Lack of clarity can mislead consumers into believing the score represents broader efficacy or safety testing.

Q: Why are before-and-after photos treated as claims? A: Before-and-after photos often imply that a product produced a specific outcome. When images depict objectively measurable improvements—such as reduced inflammation—regulators treat those images as claims requiring substantiation. Without representative evidence and controlled photographic protocols, images can mislead.

Q: Did PrettyBoy face penalties? A: NAD recommended that PrettyBoy modify or discontinue certain claims. PrettyBoy removed a “Trusted by 20,000 Men (5-star rating)” claim during the inquiry and said it would comply with NAD’s recommendations. NAD decisions carry industry weight, and failure to comply can lead to escalated review or referral to government enforcement bodies, but NAD itself does not levy monetary fines.

Q: Is a third-party seal like the National Eczema Association’s Seal of Acceptance sufficient to support therapeutic claims? A: No. A seal of acceptance typically indicates that a product’s ingredients meet criteria for tolerability or acceptability but does not demonstrate that the product therapeutically improves a condition. When advertising depicts reductions in a medical condition, clinical evidence appropriate to the claim is required.

Q: What kinds of studies satisfy NAD’s requirements for image-based or therapeutic claims? A: Competent and reliable scientific evidence generally includes well-designed clinical studies with appropriate populations, validated endpoints, sufficient sample size, controls, and blinded assessments. For photographic claims, standardized photography protocols and independent evaluations strengthen substantiation.

Q: How should advertisers use star ratings and “trusted by” claims safely? A: Advertisers should clearly identify the source and methodology for any rating, disclose the timeframe and sample size, and avoid suggesting that numbers represent broader populations if they do not. Regularly updating claims and ensuring review integrity are also essential.

Q: What should a brand do if challenged by NAD? A: Brands should respond cooperatively, produce underlying documentation, and remedy misleading claims promptly. Voluntary compliance is common and reduces reputational and regulatory risk. If a brand disagrees with a recommendation, it may appeal to the National Advertising Review Board.

Q: How long should brands keep evidence for claims? A: Retain studies, raw data and photographic originals for several years after the last use of the claim. Retention periods can vary based on industry practice and regulatory expectations, but maintaining a multi-year archive is prudent.

Q: Where can I read more NAD decisions? A: NAD decisions and case summaries are published through BBB National Programs’ case decision library and online archives. These decisions provide precedent and practical examples of how self-regulation addresses advertising claims.

Regulatory oversight of advertising is an operational reality. The PrettyBoy matter demonstrates that badges, seals and images are powerful marketing tools—and that their use carries responsibilities. Brands that align marketing claims with transparent methodology and robust evidence reduce the risk of regulatory intervention and strengthen consumer confidence.