The non-profit watch group has filed the complaint against Almay’s parent company Revlon, claiming that the brand’s #SimplyAmerican ads imply the cosmetics are made in the US, when in fact many are not.
Almay’s ads violate “the FTC's Made in the USA standards,” according to a TINA press release about the filing.
Raising brand awareness
The advertising in question showcases what Almay calls an “all-American…natural beauty look.” And the company makes a point to mention on its site that “we are very proud of our American heritage and to be a truly American brand.”
The campaign is a montage of home-town pretty, the sort that goes along with blue jeans and picnics and summer leisure, and it suggests that Almay cosmetics are the signature beauty products of women in these spaces.
The campaign includes a fund raising initiative. The brand has given $250,000 to the USO and will donate up to an additional $10,000 for social images shared with the campaign hashtag that “honor the women of the US military.”
Waiving a red flag
TINA filed the complaint to help protect consumers from deceptive marketing. "Almay's implied, unqualified claim that its cosmetics are made in the USA is false advertising," says Bonnie Patten, executive director of the advocacy group.
"Its marketing is unfair to consumers and to companies whose products really are 100% made in the US," she explains.
Almay calls attention to the “American science” which informs the brand’s product recipes: “Almay products are all formulated in our labs in Edison, New Jersey- best known as the Center of American invention (the home of Thomas Edison),” notes the company site.
TINA notes: “the company posts no disclaimers on its website or in its Almay Simply American commercials about the origins of its products” and goes on point out that “a majority of Almay's products have labels that say ‘made in the USA with U.S. and non-U.S. components,’ but do not indicate where the components are from nor how much of the foreign components are in the product,” according to the group’s release.
And TINA asserts that three of the seven products shown in a TV spot with Carrie Underwood are entirely made outside the US.
Classic American ingenuity
The patriotic branding is clearly an attempt to boost Almay sales. That brand had been performing poorly for Revlon over the past several quarters.
2015 Q1 “sales gains came mainly from its Revlon color cosmetics range, as well as the Mitchum brand, but were offset by lower Almay color cosmetic sales,” reported Cosmetics Design earlier this month.