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Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

author:World Direct Research Observation

In recent years, with the rise of the skin care ingredient party, cosmetics brands with anti-aging and anti-wrinkle effects have gradually become younger and more popular in the market, Euromonitor data shows that in 2020, the scale of anti-aging skin care products in the Chinese skin care market reached 64.6 billion yuan, accounting for 28.8% of the skin care product market share, and it is about to surpass hydrating skin care products to become the first major category in the skin care market. In the eyes of many consumers, anti-aging in a sense is equivalent to anti-wrinkle, in this context, more and more self-proclaimed anti-wrinkle properties of cosmetics have begun to appear in the public eye, "Dr. Bai anti-wrinkle essence box" is one of them.

So what kind of platform background does Dr. Bai have for this project? What is the relationship between Dr. Baiyun Shanbai and "Age Reduction New Retail"? Is there any advertising content that explicitly or implicitly suggests medical effects in dr. Baiyun Mountain Bai Anti-Wrinkle Essence Kit? Where does the saying "three minutes of light wrinkles, seven days of wrinkle removal, and fifty days of reverse growth" come from? Does the bonus system implemented by this project really have the characteristics of "no capping, no precipitation, equal dividends, and unclear performance accumulation"?

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

The background of the platform, what is the current situation

According to official information, The Anti-wrinkle Essence Kit of Dr. Baiyun Mountain Bai belongs to the scientific research project promoted by Guangzhou Baiyun Mountain Baidi Biomedical Co., Ltd. After investigation, Guangzhou Baiyunshan Bidi Biomedical Co., Ltd. was established on August 27, 2001, the legal representative Huang Ming, the registered capital of 200.25 million yuan, the shareholders are Guangzhou Baiyunshan Pharmaceutical Group Co., Ltd. (holding more than 99% of the shares), Guangzhou Pharmaceutical Research Institute Co., Ltd.

According to Dr. Bai's promoter Ah Xiu (pseudonym), Dr. Bai first started from the "age reduction new retail" project, beauty sculpture is the initial product of age reduction new retail, then chairman of the age reduction group, the founder of the beauty diamond • beauty sculpture brand or Shao Shucheng.

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

Later, age reduction new retail reached a cooperation with Baiyun Mountain of Guangzhou Medicine, which made it the current Dr. Bai. After investigation, age reduction new retail (Guangzhou) Co., Ltd. was established on September 14, 2020, the legal representative Zhang Shusheng, the shareholders are Zhang Shusheng (major shareholder) and Fu Chunbo, the registered capital of 1.3 million yuan, according to the 2020 annual report, the company's shareholders paid up capital of 0 yuan, the insured employees are also 0 people.

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

On September 14, 2021, the new product launch and signing ceremony of Dr. Baiyun Bai brand was officially held in Guangzhou, which marked the official entry of Guangzhou Pharmaceutical Baiyun mountain new retail into the beauty industry. Present at the meeting were Zhou Kejia, founder of the Baiyun Shanbai brand and president and CEO of baiyun mountain new retail project (former president of the beauty sculpture project of age reduction group and dean of age reduction business school); Wang Aiqun, head of Baiyun mountain bydy biological health business department; and Wang Xiangzun, representative of baidu biological health business department of Guangzhou Pharmaceutical Group. At the meeting, Zhou Kejia and Wang Aiqun officially completed the signing of the contract.

Hinting anti-inflammatory, is it compliant?

Baiyun Shan Bai Dr. anti-wrinkle essence set box (also known as "Baiyun Shan Bai Dr. anti-wrinkle king") is the core product of Dr. Baiyun Shan Bai, according to the product packaging, the general distributor of the product is Guangzhou Baiyun Shan Bai Di Biological Medicine Co., Ltd., the production enterprise is Guangzhou Miya Cosmetics Co., Ltd., the full name of the product is "Bai Dr. Baiboshi anti-wrinkle essence box", containing "polypeptide anti-wrinkle essence cream" and "oligopeptide solvent + dextran freeze-dried powder", The standard number of the former product implementation is Yue G Makeup Network Preparation word 2021522691, and the standard number of the latter product implementation is Guangdong G Makeup Network Preparation Word 2021522686, obviously, this product is only a domestic non-special purpose cosmetics.

However, the official public account "Dr. Bai Brand", certified by Jilin Age Reduction Biotechnology Co., Ltd., mentioned the "anti-inflammatory" effect when introducing the ingredients contained in the product.

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

Similar promotional materials are numerous online.

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

In this way, consumers may be misled by such advertising content and mistakenly believe that the product itself has a so-called anti-inflammatory effect. In this regard, Article 28 of the Advertising Law stipulates that an advertisement is false in any of the following circumstances: (2) The performance, function, place of origin, use, quality, specifications, composition, price, producer, expiration date, sales status, honors and other information of the goods, or information such as the content, provider, form, quality, price, sales status, and honors received by the service, as well as information such as promises related to the goods or services, are inconsistent with the actual situation and have a substantial impact on the purchase behavior.

In addition to the ingredients contained in the product being packaged for anti-inflammatory effects, Dr. Bai's anti-wrinkle kit itself has also been pointed out by the promotional pictures posted by the promoters as having the effect of "anti-inflammatory and antibacterial". The third step of the "Dr. Bai Anti-Wrinkle Essence Box Anti-Wrinkle Tetralogy" shows that the product has the following characteristics: "Exclusive patented ingredients, deeply conditioning the skin's water and oil balance, tightening pores; anti-inflammatory and antibacterial, inhibiting irritation; accelerating the healing of damaged cells, dispelling acne and acne scars".

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

Coincidentally, there is also a corresponding statement in the official mall (www.jlxls.net) certified by Age Reduction New Retail (Guangzhou) Co., Ltd. It is worth mentioning that Dr. Bai's dealers are now also reporting from the mall.

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

In the final analysis, cosmetics can not express or imply have anti-inflammatory effects, according to the "Cosmetics Naming Regulations", "Cosmetics Naming Guidelines" and other documents require, cosmetics claim that the language should be determined according to its language environment, prohibited words or words used include but are not limited to the following words: medical terms, words that express or imply medical effects and effects. Obviously, the "anti-inflammatory" effect advertised by the public account exceeds the definition of cosmetics, belongs to the over-scope publicity and publicity of medical effects, and belongs to illegal publicity. Article 15 of the Measures for the Administration of Cosmetic Label labeling stipulates that content that explicitly or implicitly has a medical effect is prohibited, including keywords such as "anti-inflammatory" and "anti-inflammatory". At the same time, "anti-inflammatory" has also been listed as a prohibited word for cosmetic advertising.

In order to prove that this product has a medical effect, some personal public accounts also pointed out that the product has the effect of treating "stubborn trauma of the foot" and "stubborn trauma of the hand" by posting cases.

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

Obviously, the emergence of these cases will also involve the use of assurances in the name of others or the use of implied methods to mislead their utility. Some insiders pointed out that the advertising of any product should be true and legal, and must not use the name of others to guarantee or imply that the efficacy of the product should mislead consumers. Any content that explicitly or implicitly has a medical effect, exaggerates functions, false publicity or other content that is likely to cause misunderstanding to consumers, violates relevant laws and regulations, or is suspected of false publicity.

Data support, and no source

Incidentally, the so-called "three-minute light wrinkles, seven days wrinkle removal, and fifty days of reverse growth" advertising content listed in some other promotional materials provided by the promoters when introducing the product is also suspected of containing unscientific assertions and guarantees of efficacy.

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

Similar claims can be seen repeatedly on Weibo.

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

Obviously, when listing these data, the relevant publicity materials do not clearly attach the source, source and basis of the relevant data, and according to Article 10 of the Mainland Advertising Law, the data, statistical data, survey results, abstracts, and quotations used in advertisements should be true, accurate, and indicate the source. Article 40 of the Advertising Law specifically points out that where the publication of advertisements violates the provisions of Articles 9 to 12 of this Law, the advertising supervision and management organs shall order the responsible advertisers, advertising agents, or advertising publishers to stop publishing, publicly correct them, confiscate the advertising expenses, and may also impose a fine of not less than one time but not more than five times the advertising expenses.

However, if the above data is fictitious, or the publicity personnel who post such data are unable to provide relevant materials to confirm it, then, according to the provisions of the Advertising Law, the act of using fictitious, forged or unverifiable scientific research results, statistical data, survey results, abstracts, quotations and other information as supporting materials is also false propaganda.

Team rebates, big distinction red

Next, let's pay attention to how to interpret the bonus system implemented by Dr. Bai. According to the promoter Ah Qing (pseudonym), Dr. Bai products are 1 set of 1502 yuan and two sets are 2644 yuan. The sales of one set are district generations, the cumulative sales of 5 sets are upgraded to the county generation, the cumulative sales of 30 sets are upgraded to the municipal generation, the cumulative sales of 300 sets are upgraded to the provincial generation, and the cumulative sales of 1000 sets are upgraded to the regional generation. The specific sources of income are detailed in the following information:

Dr. Bai: Cosmetics imply medical effects such as anti-inflammatory, how to interpret the eight-level agency model?

It is worth mentioning that the above information has not yet reflected the following points:

First, the tie award is forty percent.

Second, according to the existing policy, the consumption of 2664 yuan to get two sets of products can upgrade the county generation; the consumption of 11132 yuan as a point can upgrade the municipal generation.

Third, the recommender permanently binds the relationship and takes an infinite generation difference.

Fourth, the region can take unlimited generations of team rebates (team rebates are calculated as flowing dividends, and repurchase performance is also counted as turnover), 2% to 10%. 0 to 500,000 corresponds to two points, one point is incremented for every 500,000, and the rebate point of more than 4.5 million is 10%.

Fifth, the performance of the region has reached 4.5 million, and there are also regions within the team that have reached 4.5 million performance, and when the performance of the small market reaches 1.5 million, then it can be upgraded to a golden region, and the golden region can take 30% of the flow of the golden region within the team. Above the Gold Zone are the Diamond Zone and the Crown Zone. In other words, if you count the three levels of gold region, diamond region and crown region, Dr. Bai should belong to the eight-level agent model to some extent.

Postscript

In recent years, the chaos of individual unscrupulous merchants implying that cosmetics have a medical effect through product ingredients has occurred frequently. In order to curb the continued emergence of this chaos, from May 1, 2022, the "Measures for the Administration of Cosmetic Labels" issued by the State Food and Drug Administration will be officially implemented. The Measures stipulate that cosmetic labels are prohibited from using or claiming assertions or guarantees of efficacy and safety; it is forbidden to imply that the product does not actually have or is not allowed to claim efficacy by declaring the function of the raw materials used. It can be seen that cosmetic labels have been prohibited from implying medical effects through product ingredients, pushing one or the other, and the relevant advertising content involving cosmetics is likely to be inconsistent with regulations.

As for dr. Bai's future development? Can the false publicity problems surrounding related products be paid attention to and rectified by the operator? In this regard, the micro-business e-commerce research will continue to pay attention.

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Source: WeChat E-commerce Survey