National Advertising Division Recommends P&G Discontinue or Modify Comparative Advertising Commercials for Puffs Ultra Soft Tissues vs. Kleenex

 New York, NY – November 8, 2022 – Acting on a challenge brought by Kimberly-Clark Corporation, the National Advertising Division (NAD) of BBB National Programs recommended that The Procter & Gamble Company (P&G) discontinue two commercials for Puffs Ultra Soft Tissues or modify them to:

• Avoid conveying a misleading message about the softness, comfort, or safety of Kleenex tissues; and
• Avoid conveying the misleading message that Puff’s tissues have visible quilt-like puffing.

At issue before NAD was whether two short, whimsical video commercials featuring animated characters and side-by-side product comparisons between Puffs tissues and the “leading” competitor convey disparaging messages about Kleenex.

Although humor can be an effective and creative way for advertisers to highlight the differences between their products and those of competitors, humor and hyperbole do not relieve an advertiser of the obligation to support messages that their advertisements might reasonably convey.

NAD concluded that one reasonable message conveyed by the challenged commercials, “Linda’s Little Nose” and “Fire Department,” is that competing tissues, including Kleenex, are harsh, insufficiently soft, and harmful to the nose. Because this message was not supported by P&G’s evidence, NAD recommended that the advertising be discontinued or modified to avoid conveying a misleading message about the softness, comfort, or safety of Kleenex tissues.

NAD also considered whether the side-by-side demonstration scene in “Linda’s Little Nose,” a simulation of a structural feature of P&G’s product, conveys the message that Puffs have quilted puffing when the tissues are actually flat. NAD noted that an advertiser may artfully arrange a product to look appealing in the advertising but may not materially or artificially enhance the product beyond the scope of supporting evidence.

NAD determined that the side-by-side demonstration conveys a misleading message about the appearance of Puffs tissues not supported by the evidence and recommended that the advertising be discontinued or modified to avoid conveying the misleading message that Puff’s tissues have visible quilt-like puffing.

During the proceeding, P&G permanently discontinued the claim that Puff is “air fluffed with 40% more cushiony thickness” [“*vs. the Leading Ultra Soft Competitor”]. Therefore, NAD did not review this claim on the merits.

In its advertiser statement, P&G stated that it “will comply with NAD’s recommendations” and “appreciates NAD’s careful review of this matter.” The advertiser further stated that while it “respectfully disagrees with NAD’s decision, because P&G is a strong supporter of the self-regulatory process it will take NAD’s recommendations into account in future advertising for Puffs tissues.”

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.

About BBB National Programs: 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.

About the National Advertising Division: 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.