Response from the ASA

Dear Mr Kennick

SSL / FULL MARKS

Thank you for contacting the Advertising Standards Authority. I'm sorry to hear that this ad has caused you concern.

We've previously considered objections and reviewed the claim in question; we also took advice from the Medicines and Healthcare products Regulatory Agency (MHRA). I should advise you from the outset, however, that we don't consider that our rules have been breached on this occasion.

The MHRA confirmed that Full Marks is a medical device, because the product claims to kill lice by a physical means. Medicines work by pharmacological, metabolic or immunological means. The product contains a substance called isopropyl myristate (propan-2-yl tetradecanoate) which works by dehydrating the lice, therefore killing the lice by a physical means. Therefore the claim "without pesticides" is likely to be a reference to the fact that the product contains no organophosphate-type ingredients. We don't consider that the ad will create an emotional impression of the product - the claim "without pesticides" only appears in a manner-of-fact fashion.

I appreciate that this may not have been the response you were hoping for, but I hope I have shown that we've considered your objections carefully and thoroughly before reaching our decision. Thank you, once again, for taking the time to contact us with your concerns.

Advertising Standards Authority
Mid City Place 71 High Holborn London WC1V 6QT
Telephone 020 7492 2222 www.asa.org.uk
Keeping advertising standards high