Ad (f) stated that “billions of cells including bacteria […] reside in our guts and are responsible for many vital bodily processes. This includes things like: helping to control digestion […] Our good gut bugs are important for digestion and destroying any harmful bacteria that may emerge […] certain factors […] can lead to gut dysbiosis”. In that context, we considered the claim that Willy’s ACV could “help to repopulate some of the good bacteria in your gut” would be understood to mean that the presence of “good” bacteria, provided by Willy’s ACV products, could help the process of digestive transit and counter any ill effects of gut dysbiosis. Similarly, we considered the claim “Help balance ph[sic] in the gut, leading to improved digestion” in ad (a) implied that the pH balance of the gut could be unbalanced and that if it was, digestion might be negatively affected, and that the product could help to correct that and improve digestive transit. We further considered the claims “can also help with digestion” in ad (b) and “boost digestion” in ad (c) would also be understood to mean the product could improve digestive transit. Claims to help or improve the process of digestive transit were specific health claims. Willy’s ACV stated that they would, if the substantiation provided was deemed unsuitable, make changes, in particular to the claims about reduction of disease risk, and claims to prevent, treat or cure disease. Assessment Rhian Stephenson, nutritionist, ex-CEO of Psycle and founder of supplements brand Artah Health, has felt the effects herself and fully supports a daily dosage of apple cider vinegar. “Personally, I find that it helps with my digestion and blood sugar control, especially when I'm overtired. Apple cider vinegar isn't a magic bullet, but it does have proven benefits when it comes to blood sugar regulation, postprandial insulin response, appetite and satiety, and potentially, managing cholesterol levels."

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.

A 2020 US study found that, yes, apple cider vinegar could help regulate blood glucose concentrations and be of help to those with type two diabetes. And further research found links between apple cider vinegar intake and reduced cholesterol – but take note: that was just a small study, and there's more testing to be done. 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. We welcomed Willy’s ACV’s assurance that the claims would be amended. However, because the ads made claims to prevent, treat or cure human disease, we concluded they breached the Code.

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. Because we had not seen any evidence that the specific health claims in ads (a), (b), (c), (e), and (f) were authorised on GB NHC Register, and ads (a), (b), (c) and (d) made general health claims that were not accompanied by specific authorised health claims, we concluded they breached the Code. Ad (b) included the claims “to avoid the terrible winter flus”, “Struggling to fight a pesky cold?”, “this ACV is a flu season must have” and “#FluSeason”. Ad (d) included the claims “With the nights drawing in, days getting shorter and flu season taking hold, now’s the time to focus on our immunity and what we do to prevent getting ill this season. Apple cider vinegar (ACV) has been used as a natural remedy for centuries […] recent research and anecdotal stories have suggested that ACV may also help” and “reduce the symptoms of, or even prevent colds and flu”. We considered those claims would be understood as either direct or implied claims that apple cider vinegar could help to prevent, treat or cure colds or the flu.We first assessed which claims were specific health claims and which therefore must be authorised on the GB NHC Register.

We considered the claims “I feel better than I have for years”, “feel the difference to your wellness”, “to help you feel fantastic”, “daily dose of natural goodness”, “I can vouch for the benefits myself, it’s changed my life”, “Gently […] rejuvenating” and “wellness tonic” in ad (a) were references to how apple cider vinegar products provided general good health. We considered the claim “promote healthy aging” in ad (b) would be similarly understood, although in the context of aging in particular. 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.

Ad (b) also included the claim that cayenne pepper was “beneficial against infections” and ad (e) featured the claim “antimicrobial”. Antimicrobials were substances that killed microorganisms or prevented them from growing and causing disease. We therefore considered both claims would be understood as meaning the products could prevent viral and bacterial infections, and therefore were claims to prevent, treat or cure human disease. Add into most meals including coups, salads, roasted veg and meat basting. Use in sauced, dressing, dips and marinades. Whizzy Salad Dressing ACV is a natural remedy that has been used for thousands of years in cooking and medicine. We recommend using this in your cooking to add depth of flavour and take advantage of the health benefits - whether this be as a dressing on your salad, drizzled over roasted vegetables or for caramelising onions. Classic Daily Dose 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. The CAP Code stated that only reduction of disease risk claims authorised on the GB NHC Register could be used in marketing communications. Reduction of disease risk claims were health claims that stated, suggested or implied that the consumption of a food or one of its constituents significantly reduced a risk factor in the development of human disease.

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 On that point, ads (a), (b), (c), (d), (e) and (f) breached CAP Code (Edition 12) rules 15.1, 15.1.1, and 15.2 (Food, food supplements and associated health or nutrition claims). Ads (b) and (c) included the claim “loaded with antioxidants”, and ad (b) also included the claim “Ginger – loaded with antioxidants” in relation to the Fire Cider product. We considered those claims were specific health claims that the products, or ingredients in them, helped to protect cells from oxidative stress. 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). ActionWe considered the claims “play a part in bone and heart health” in ad (c) and “improving heart health” in ad (d) were references to the products promoting general good health of the bones and heart. We considered the claims “Good gut” and “gut-healthy goodness” in ad (a) and “#GutHealth” in ad (b) would be understood as meaning that the products were good for the overall general health of the gut. We considered the claims “Live probiotic foods” in ad (a) would be understood similarly, because consumers were likely to understand the word “probiotic” as describing a substance that contributed to the general good health of the gut. For the same reasons we considered the claim “with premium live probiotics to boost gut health” in ad (a) would also be understood as a reference to general health of the gut. All the above claims were therefore general health claims for the purposes of the Code. However, none of the claims were accompanied by relevant, authorised specific health claims as was required. On that point, ads (a), (b), (c), (d) and (e) breached CAP Code (Edition 12) rules 15.6 and 15.6.2 (Food, food supplements and associated health or nutrition claims). Ad (c) included the claim “help with memory & cell production”. We considered those claims would be understood as meaning the product would support the brain processes involved in sorting and retrieving memories and support normal cell production in the body, which 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).