What this checklist is for
This checklist concerns advertising for non-surgical body treatments. It is about what marketing communicates, rather than whether a treatment worked for an individual, whether a procedure was performed safely, or whether a contract should be cancelled. It is intended for material aimed at UK consumers, including clinic websites, paid search listings, social-media posts, emails, leaflets, posters and other promotional content.
The Advertising Standards Authority, generally known as the ASA, administers the UK advertising codes. For most non-broadcast marketing communications, the relevant code is the CAP Code, written by the Committee of Advertising Practice. The code includes rules intended to prevent misleading advertising and requires marketers to hold evidence for claims where substantiation is needed.
A complaint is usually clearer when it identifies particular words, images, measurements or implied outcomes. A broad objection to a treatment category may not tell the ASA what it should assess. For example, the issue may be a statement that a result is permanent, an image that appears to show a typical outcome, or a qualification that is difficult to see beside a prominent headline.
An ASA complaint may lead to a decision on an advert. It does not award compensation, determine clinical negligence, compel a refund or assess an individual's medical condition. Those matters can require a separate route. Keeping advertising, treatment, payment and health concerns in distinct records helps preserve useful evidence and reduces the risk of sending a complaint to a body unable to decide it.
Core question: Does the advert give an ordinary consumer a potentially misleading impression about the treatment, its likely outcome, its safety, its status or the terms on which it is offered?
Work through the checklist before making a submission. It is not necessary to identify every possible issue. One specific concern, supported by a complete record of the advert, may be enough to make the point capable of assessment.
Gather the advert and identify the claim
Save the advert in the form in which you saw it. Take screenshots showing the complete page or post, account or advertiser name, date, platform, captions, claims, qualifications and any booking prompt. For a video, preserve the recording where possible and note spoken claims. The ASA asks complainants for enough detail and evidence to identify the advertisement under complaint.
Record where, when and how it appeared. Note whether it was a website page, paid search result, email, social-media post, leaflet or poster. State the date seen and, where relevant, whether the material appeared to be targeted at UK consumers. Online content can be amended or removed quickly, so a dated record can matter even where the wording seems straightforward.
Identify the exact claim, including the implied message. Copy the headline, phrase, call to action or caption. Then state the likely consumer takeaway. This might be a promise of permanent fat loss, a guaranteed measurement change, a claim that an outcome is typical, or an implication that a treatment is suitable for anyone. Under the CAP Code, marketing communications must not materially mislead or be likely to do so.
Separate the main claim from background material. A page may contain a bold promise, testimonials, photographs, a booking button and small-print conditions. Preserve all of them. The overall impression can matter more than one limited sentence in isolation. Equally, avoid extracting a phrase in a way that removes important context, such as a clear limitation placed immediately beside the claim.
A useful complaint does not need to decide whether every statement on a page is wrong. Its purpose is to show what was published, what a consumer was likely to understand, and why that impression appears capable of breaching an advertising standard.
Assess evidence, images and treatment language
Check whether evidence is presented as proof. Expressions such as clinically proven, scientifically proven, permanent, safe or works can amount to objective claims. CAP Code rule 3.7 requires documentary evidence for objective claims capable of objective substantiation. Explain why the claim appears broader than any support visible in the advert. Do not say that evidence does not exist merely because it is not displayed.
Check qualifications, exclusions and small print. Record whether a material limitation is absent, unreadable, far from the headline, contradicted elsewhere, or disclosed only after contact. CAP Code rules on misleading advertising address material information that is omitted or presented unclearly, ambiguously or too late. A qualification may clarify a claim, but it may not correct a headline that produces the opposite overall impression.
Examine photographs and measurements as claims. Preserve before-and-after images with captions and surrounding text. Note whether lighting, pose, clothing, timing, number of treatments, weight change, diet, exercise, surgery or other relevant factors are explained. An image can communicate an efficacy claim without stating a percentage. CAP guidance on weight-control and slimming advertisements may be relevant where imagery suggests a body-change result.
Check medical, safety and professional-status language. Record claims that a treatment is medical, approved, cleared, risk-free, suitable for everyone or performed by a stated type of professional. The CAP Code includes rules for health, beauty and slimming advertisements. A regulatory term should be considered for the impression it creates for a UK consumer, rather than treated as a general indication of effectiveness or suitability.
Check urgency, packages and guarantees separately. Preserve countdowns, claims that an offer ends that day, deposits described as non-refundable, guaranteed outcomes and assertions that a course is necessary. The CAP Code contains rules on misleading actions, omissions and promotional marketing. A complaint can concern the accuracy of an urgency claim or guarantee without needing to reach a conclusion about the treatment's clinical merit.
Keep the complaint proportionate to the evidence available. It is usually stronger to identify one or two precise issues than to make a long series of conclusions that the advert itself does not establish.
Which standard applies to which concern?
This decision table is a working aid, not a substitute for the ASA's own remit decision. It distinguishes common advertising concerns from the material that can help explain them. The named source in each row is the relevant standard or body to consult when framing the point.
| What you see | What to check | Standard or body behind it |
|---|---|---|
| A promised body-change result | Whether the result is objective and whether support appears adequate for the breadth of the claim | CAP Code rule 3.7 on substantiation |
| A headline that conflicts with small print | Whether a material limitation is clear, prominent and timely enough to affect the overall impression | CAP Code rules on misleading advertising |
| Before-and-after images | Whether the images imply efficacy without material context about what produced the change | CAP guidance on weight-control and slimming advertisements |
| Medical, approval or safety language | What the term means, who made the decision and whether it implies proven effectiveness or universal suitability | CAP Code section on health, beauty and slimming advertisements |
| A discounted course ending soon | Whether the availability, deadline or stated saving is presented accurately | CAP Code section on promotional marketing |
| A social-media post | Whether it is marketing and whether the advertiser has sufficient control over the content | ASA remit guidance and the CAP Code |
A standard is not a menu of automatic outcomes. The ASA considers wording, imagery, placement, audience and context. A screenshot of the complete post or page is therefore generally more useful than a cropped sentence that removes the qualification, image or booking prompt.
Distinguish an advert complaint from other problems
A treatment can be misleadingly advertised even where nobody has undergone it. Equally, someone may have a serious concern after treatment although the advert itself was not misleading. These are separate questions and may need separate action.
If the immediate concern is symptoms, an adverse reaction or worsening health, seek appropriate clinical advice without waiting for an advertising outcome. A complaint to the ASA is not an urgent safety-reporting route and does not assess an individual's medical condition. Preserve the advertising material if possible, but place health needs first.
If the issue is payment, cancellation, a package that differs from what was sold, or a service not performed with reasonable care and skill, consumer-law routes may be more relevant. The Consumer Rights Act 2015 sets standards for services supplied to consumers, although whether it applies to a particular contract depends on the facts. Citizens Advice provides consumer guidance and receives information that can assist enforcement work by Trading Standards services.
If the concern is unauthorised use of a photograph, a false professional-registration claim, or an allegation that a regulated professional has breached professional standards, the appropriate recipient may be the platform, relevant regulator or another public authority. Do not assume that an ASA ruling decides those matters.
Use a simple division in your records. Keep one file or folder for the advert, including screenshots and a short account of the alleged misleading impression. Keep a separate chronology for any consultation, payment, consent material, treatment, symptoms and communications. This makes it easier to send the appropriate material to each organisation.
Prepare a concise ASA submission
Start with one sentence identifying the advertiser, medium and date on which the material was seen. Next, quote the particular claim and describe its likely meaning to an ordinary consumer. Then explain why it may be misleading, unsupported or inadequately qualified. Attach or upload the complete evidence.
A practical structure is: The advert states [words]. In context, including [image or headline], it appears to claim [consumer takeaway]. I consider this may be misleading because [reason]. I have attached [screenshots or recording]. This is not legal wording. It is simply a clear way to locate the alleged problem and explain why it matters.
Avoid presenting clinical conclusions as settled where the material available to you does not establish them. It can be enough to say that the advertiser appears to make an objective claim and that you have not seen substantiation for the scope of that claim. The CAP Code places responsibility on marketers to hold evidence before publication where substantiation is required.
Include the platform and date because online advertising may be amended, reposted or shown differently to different users. For an email, retain headers where possible. For temporary stories or video, record the account name, time and all visible frames. If a claim was made orally during a consultation, make a dated contemporaneous note, while recognising that the ASA may have less published material to assess.
Do not provide personal medical information unless it is necessary to explain the advertising issue. If your evidence includes another person's image or contact details, consider whether those details can be redacted while retaining the relevant claim, caption or context.
Limits of this checklist
This checklist applies to UK-facing marketing for non-surgical body treatments. It does not decide whether a named device is effective, whether a particular person is a suitable candidate, or whether an individual result is clinically significant. It also does not cover surgical body procedures, prescription decisions or detailed product and device classification.
It is not a guarantee that the ASA will investigate, uphold a complaint or require a particular outcome. The ASA first considers whether material falls within its remit and whether there is a potential issue under the advertising codes. Some content, including private consumer communications or editorial material without a marketing purpose, may not be treated in the same way as an advertisement.
This is not tailored legal, medical or financial advice. It may not apply in full where an advert is directed outside the UK, where broadcaster material is involved, or where another statutory regulator has a primary role. Broadcast advertising uses the BCAP Code, also administered by the ASA, rather than the CAP Code used for most non-broadcast advertising.
Finally, an upheld advertising complaint is not a finding that every treatment delivered by an advertiser was unsafe or ineffective. It concerns a particular advertisement or advertising practice. Keep that distinction clear when describing any outcome to others or when deciding whether a separate complaint route is needed.