Ad (a) also included the claim that Sir Ranulph Fiennes had said apple cider vinegar “helped relieve his arthritis symptoms” and ad (d) stated “Apple cider vinegar (ACV) has been used as a natural remedy for centuries – […] helping arthritis symptoms”. We considered those were claims that apple cider vinegar could help to treat a human disease. A listing for an “APPLE ACV KOMBUCHA DRINKS CUBE” featured the claim “Gently energising and rejuvenating”. The CAP Code prohibited claims that stated or implied that a food could prevent, treat or cure human disease.Ad (a) included the claims “Can shrink swelling in the body” and “Anti-inflammatory”; ad (b) included the claim “Turmeric and Cayenne pepper – turmeric is known to contain anti-inflammatory properties” and the claim “Loaded with […] anti-inflammatory properties” in relation to the Fire Cider product; and ad (c) included the claims “loaded with […] anti-inflammatories” and “Overall loaded with anti-inflammatory properties”. We considered those claims would be understood to mean the product could help to treat inflammation in the body, and were therefore claims to treat or cure human disease. We considered the claim “speed up your metabolism” in ad (b) would be understood to mean the product would speed up the metabolism, and that in turn would help with weight management and weight loss. Ad (a) also included the claim that the product “helped … lose weight”. Those claims were specific health claims.

On that point, ads (a), (b) and (d) breached CAP Code (Edition 12) rules 15.6 and 15.6.2 (Food, food supplements and associated health or nutrition claims). The CAP Code defined health claims as those that stated, suggested or implied that a relationship existed between a food category, a food or one of its constituents and health. Willy’s ACV had provided third-party articles in support of the health claims made in the ads. However, only specific health claims authorised on the Great Britain nutrition and health claim (NHC) register (the GB NHC Register) could be made in ads promoting food or drink products. Any authorised health claims made in an ad must meet the associated conditions of use. Additionally, the Code required that general health claims, which were claims that referred to the general benefits of a nutrient or food for overall good health or health-related well-being, must be accompanied by a specific authorised health claim. Willy’s ACV had not provided evidence that their products contained any foods or nutrients for which there were authorised reduction of disease risk claims on the GB NHC Register. We therefore concluded that the claims relating to the lowering of cholesterol and blood pressure breached the Code. On that point, ad (a) breached CAP Code (Edition 12) rules 15.6 and 15.6.6 (Food, food supplements and associated health or nutrition claims). Action

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Ad (a) included the claims “Helped me lower my cholesterol” and “I have lowered my cholesterol”; ad (b) included the claim that the garlic in the Fire Cider product “has reports of […] lowering cholesterol"; and ad (d) featured the claim that apple cider vinegar had been used as a natural remedy for “reducing cholesterol levels”. We considered consumers would understand those claims to mean that the apple cider products could reduce levels of cholesterol. High cholesterol was a risk factor in the development of heart disease and the claims were therefore reduction of disease risk claims. ads (a), (b), (c), (d) and (e) made claims to prevent, treat or cure disease, which were prohibited by the Code; and

We considered some consumers may not be familiar with the term “adaptogens”, used in ad (a). However, we understood the term was used to describe natural substances believed to help the body respond to stress, and we considered many consumers who were interested in the potential health benefits of products such as apple cider vinegar would have some knowledge of that definition. We therefore considered the claim “[…] with adaptogens” would be understood to mean that the product would support the body’s ability to respond to stress, which we considered was a specific health claim. Ad (e) included the claims “great for curbing sugar cravings” and “may also regulate blood sugar and insulin levels, which can lead to a reduction in sugar cravings”. We considered the claims would be understood to be specific health claims that the product could support the body’s ability to process sugar, and so support the regulation of blood glucose and insulin levels and increase feelings of satiety, particularly in relation to sugar consumption. Enjoy a daily dose first thing in the morning or 30 minutes before meals. Take 25ml diluted in a smoothie, in warm water with lemon and honey or in other creative ways. Salt/Caffeine SwapThe ads must not appear again in their current form. We told Willy’s Ltd t/a Willy’s ACV to ensure their advertising did not include: general health claims for foods unless they were accompanied by a specific authorised health claim for which the food met the conditions of use; unauthorised specific health claims or reduction of disease risk claims, or authorised health claims or reduction of disease risk claims for which the food did not meet the conditions of use for the claim; claims to prevent, treat or cure human disease; or health claims that referred to a rate or amount of weight loss. Ad (b) included the claim “Horseradish – known to boost circulation […]” in relation to the Fire Cider product. Ad (a) featured the claim “I sleep better” and the claims “increased my energy levels” and “Gently energising”. We considered that claims to boost circulation, improve sleep and increase energy levels were specific health claims. The post went on to include as helpful tips “Rebalance your microbes by eating a diverse diet rich in live and fermented foods/drinks […] Because our ACV is alive with our 300 year old mother, getting your daily dose of ACV can help to repopulate some of the good bacteria in your gut”. Issue