The Influencer Market and Consumer's Deception: The Mama Earth

I.          Introduction

The Consumer Protection Act, 2019, defines “advertisement” as any publicity, representation, endorsement or pronouncement message across media. “Misleading advertisement” is defined as one that gives a false description or a false guarantee, misleads consumers about its nature, substance, or quantity, constitutes unfair trade practice, or deliberately conceals important information. Advertising shapes consumer choices and drives brand success; however, its impact hinges on transparency across evolving modes. The advertisements nowadays focus on a trust-driven approach through influencer marketing. Brands pay social media influencers with money, free products, or partnerships to endorse their products, allowing them to connect with audiences by sharing relatable stories and recommendations, making their promotions feel authentic. Such advertisements blur the thin line between truth and persuasion, and catchy claims outpace accountability.

This approach is particularly impactful in the beauty and personal care industry, where the “clean,” “natural,” and “chemical-free” narrative has gained massive appeal. A key problem arises as the line between genuine recommendations and paid promotions is often unclear, exploiting consumer trust. Mamaearth, launched in 2016 under Honasa Consumer Ltd., markets itself as a “natural, toxin-free, and dermatologically tested” personal care brand. It has rapidly scaled as one of India's leading D2C beauty and personal care companies, largely through influencer marketing.  

II.         Deconstructing Mamaearth's Influencer Marketing Strategy

Mamaearth’s products dominate social media through paid collaborations with beauty influencers on Instagram, YouTube, and short-form video platforms, driving significant growth. Honasa reported INR 595 Cr in revenue for Q1 FY26. However, celebrities and micro-influencers commonly present unrealistic outcomes with limited transparency and disclosure. A promotional advertisement featuring Shilpa Shetty underscores a discrepancy; the claim of being “toxin-free” lacks scientific precision, and the use of the term “natural” does not inherently guarantee safety.

Advertisements promise rapid or dramatic results, such as “Reduces Acne in 3 Days,” “Eliminates Tan”, or “Baby Soft Skin.” These lack clinical evidence, omit disclaimers in ads, and are rationally unattainable as results vary by user. Terms like “Dermatologically Tested” and “Safe for Babies” build perceived credibility, but they merely mean minimal patch testing, not universal safety or endorsement. Influencers promote benefits like “Reduces Hair Fall,” “Boosts Skin Health,” or “Protects from Toxins”, often lacking robust evidence.

Mamaearth Onion hair oil, marketed as a hair growth solution, primarily consists of carrier oils like sesame, castor, and coconut, which temporarily reduce breakage and enhance hair's appearance. Real onion oil appears lower in the ingredients list, that does not disclose the concentration ratios. This highlights “hero ingredient” marketing, where a trendy ingredient is emphasised despite its low concentration for perceived efficacy. Another misleading element is price and promotional claims that frequently omit terms like “up to” or “T&C apply,” creating false expectations of universal discounts.

Furthermore, visual loopholes, such as buried disclosures, absent thumbnail tags, or omitted story labels, systematically undermine transparency in Mamaearth’s ads. Simultaneously, lab coats, plants, and mother-baby imagery create false impressions of clinical validation and enhanced safety. Additionally, greenwashing narratives serve to mitigate complaints, as consumers often overlook vagueness in favour of trust.

III.       The Legal Labyrinth

The Advertising Standards Council of India (“ASCI”) prohibits unsubstantiated, absolute, or misleading statements, requiring evidence for all descriptions, claims and comparisons, which relate to matters of objectively ascertainable fact.  The Supreme Court held that protection under Article 19(a) does not extend to advertising that is “deceptive, unfair, misleading and untruthful”, directly negating any potential free speech defence for misleading advertisements. In FY24, Honasa emerged as the largest advertising violator, with 187 recorded instances of non-compliance.  

Mamaearth claims to be Asia’s 1^st Brand with Made Safe™ certified products that are free of all known toxins banned in most countries. However, this assertion appears superficial, as the company’s website lists only 23 products as certified, without providing any supporting documentation or verifiable evidence. Made Safe also does not recognise Mamaearth as a certified brand. Claims of QACS Lab testing and FDA approval are likewise unsupported.

Mamaearth’s promotions can be legally challenged on the following grounds. Firstly, claims like “100% toxin-free” or “safe for babies” go beyond mere puffery. The Supreme Court emphasised the evaluation of the actual impact on consumer perception, rather than solely the textual content of the advertisement. Secondly, Dabur India Ltd. v. Colortek Meghalaya Pvt. Ltd. reinforced the principle that unverified “health” claims violate advertising standards set by ASCI by constituting deceptive advertising, including claims to treat conditions like acne. Thirdly, the principle that “natural” claims must be substantiated was most recently and forcefully affirmed by the apex court in Indian Medical Association v. Union of India. The ASCI Code states that certain claims be appropriately explained to ensure that consumers with average intelligence are not misled or deceived by means of implications or omissions.

Moreover, the ASCI mandates clear disclosure labels like #Ad, #Sponsored, #Collab, or #PaidPartnership in the first viewable section of posts. Mamaearth's collaborations often fail this. Consumers may view such messages without realising the commercial intent of these, and that becomes inherently misleading. Thereby, the code requires the advertisements featuring celebrities to ensure that claims made in them are not misleading, false or unsubstantiated. It also advises the influencers to review and satisfy themselves that the advertiser is in a position to substantiate the claims made in the advertisement.

IV.       Conclusion

Despite repeated violations, legal enforcement against Mamaearth remains limited. The brand’s reliance on emotionally persuasive “natural” and “eco-friendly” narratives reduces complaints. Vague claims such as “clinically tested” are difficult to contest due to inaccessible evidence for ordinary consumers. Regulatory gaps persist, as terms like “toxin-free” or “natural” lack statutory definitions. Additionally, ASCI’s rulings are advisory and non-binding in nature. Decentralised use of multiple micro-influencers across platforms undermines effective surveillance and enforcement.  Aligning claims with reality requires collaboration among regulators, platforms, and ethical industry players. Platforms must have enhanced disclosure requirements, mandatory verification systems, and algorithmic demotion of misleading promotions. Legislative reforms are required to strengthen penalties, harmonise symbols and labels across platforms, and ensure consistent terminology worldwide. Furthermore, consumer awareness and digital literacy are essential for a meaningful change.

I.          Introduction

The Consumer Protection Act, 2019, defines “advertisement” as any publicity, representation, endorsement or pronouncement message across media. “Misleading advertisement” is defined as one that gives a false description or a false guarantee, misleads consumers about its nature, substance, or quantity, constitutes unfair trade practice, or deliberately conceals important information. Advertising shapes consumer choices and drives brand success; however, its impact hinges on transparency across evolving modes. The advertisements nowadays focus on a trust-driven approach through influencer marketing. Brands pay social media influencers with money, free products, or partnerships to endorse their products, allowing them to connect with audiences by sharing relatable stories and recommendations, making their promotions feel authentic. Such advertisements blur the thin line between truth and persuasion, and catchy claims outpace accountability.

This approach is particularly impactful in the beauty and personal care industry, where the “clean,” “natural,” and “chemical-free” narrative has gained massive appeal. A key problem arises as the line between genuine recommendations and paid promotions is often unclear, exploiting consumer trust. Mamaearth, launched in 2016 under Honasa Consumer Ltd., markets itself as a “natural, toxin-free, and dermatologically tested” personal care brand. It has rapidly scaled as one of India's leading D2C beauty and personal care companies, largely through influencer marketing.  

II.         Deconstructing Mamaearth's Influencer Marketing Strategy

Mamaearth’s products dominate social media through paid collaborations with beauty influencers on Instagram, YouTube, and short-form video platforms, driving significant growth. Honasa reported INR 595 Cr in revenue for Q1 FY26. However, celebrities and micro-influencers commonly present unrealistic outcomes with limited transparency and disclosure. A promotional advertisement featuring Shilpa Shetty underscores a discrepancy; the claim of being “toxin-free” lacks scientific precision, and the use of the term “natural” does not inherently guarantee safety.

Advertisements promise rapid or dramatic results, such as “Reduces Acne in 3 Days,” “Eliminates Tan”, or “Baby Soft Skin.” These lack clinical evidence, omit disclaimers in ads, and are rationally unattainable as results vary by user. Terms like “Dermatologically Tested” and “Safe for Babies” build perceived credibility, but they merely mean minimal patch testing, not universal safety or endorsement. Influencers promote benefits like “Reduces Hair Fall,” “Boosts Skin Health,” or “Protects from Toxins”, often lacking robust evidence.

Mamaearth Onion hair oil, marketed as a hair growth solution, primarily consists of carrier oils like sesame, castor, and coconut, which temporarily reduce breakage and enhance hair's appearance. Real onion oil appears lower in the ingredients list, that does not disclose the concentration ratios. This highlights “hero ingredient” marketing, where a trendy ingredient is emphasised despite its low concentration for perceived efficacy. Another misleading element is price and promotional claims that frequently omit terms like “up to” or “T&C apply,” creating false expectations of universal discounts.

Furthermore, visual loopholes, such as buried disclosures, absent thumbnail tags, or omitted story labels, systematically undermine transparency in Mamaearth’s ads. Simultaneously, lab coats, plants, and mother-baby imagery create false impressions of clinical validation and enhanced safety. Additionally, greenwashing narratives serve to mitigate complaints, as consumers often overlook vagueness in favour of trust.

III.       The Legal Labyrinth

The Advertising Standards Council of India (“ASCI”) prohibits unsubstantiated, absolute, or misleading statements, requiring evidence for all descriptions, claims and comparisons, which relate to matters of objectively ascertainable fact.  The Supreme Court held that protection under Article 19(a) does not extend to advertising that is “deceptive, unfair, misleading and untruthful”, directly negating any potential free speech defence for misleading advertisements. In FY24, Honasa emerged as the largest advertising violator, with 187 recorded instances of non-compliance.  

Mamaearth claims to be Asia’s 1^st Brand with Made Safe™ certified products that are free of all known toxins banned in most countries. However, this assertion appears superficial, as the company’s website lists only 23 products as certified, without providing any supporting documentation or verifiable evidence. Made Safe also does not recognise Mamaearth as a certified brand. Claims of QACS Lab testing and FDA approval are likewise unsupported.

Mamaearth’s promotions can be legally challenged on the following grounds. Firstly, claims like “100% toxin-free” or “safe for babies” go beyond mere puffery. The Supreme Court emphasised the evaluation of the actual impact on consumer perception, rather than solely the textual content of the advertisement. Secondly, Dabur India Ltd. v. Colortek Meghalaya Pvt. Ltd. reinforced the principle that unverified “health” claims violate advertising standards set by ASCI by constituting deceptive advertising, including claims to treat conditions like acne. Thirdly, the principle that “natural” claims must be substantiated was most recently and forcefully affirmed by the apex court in Indian Medical Association v. Union of India. The ASCI Code states that certain claims be appropriately explained to ensure that consumers with average intelligence are not misled or deceived by means of implications or omissions.

Moreover, the ASCI mandates clear disclosure labels like #Ad, #Sponsored, #Collab, or #PaidPartnership in the first viewable section of posts. Mamaearth's collaborations often fail this. Consumers may view such messages without realising the commercial intent of these, and that becomes inherently misleading. Thereby, the code requires the advertisements featuring celebrities to ensure that claims made in them are not misleading, false or unsubstantiated. It also advises the influencers to review and satisfy themselves that the advertiser is in a position to substantiate the claims made in the advertisement.

IV.       Conclusion

Despite repeated violations, legal enforcement against Mamaearth remains limited. The brand’s reliance on emotionally persuasive “natural” and “eco-friendly” narratives reduces complaints. Vague claims such as “clinically tested” are difficult to contest due to inaccessible evidence for ordinary consumers. Regulatory gaps persist, as terms like “toxin-free” or “natural” lack statutory definitions. Additionally, ASCI’s rulings are advisory and non-binding in nature. Decentralised use of multiple micro-influencers across platforms undermines effective surveillance and enforcement.  Aligning claims with reality requires collaboration among regulators, platforms, and ethical industry players. Platforms must have enhanced disclosure requirements, mandatory verification systems, and algorithmic demotion of misleading promotions. Legislative reforms are required to strengthen penalties, harmonise symbols and labels across platforms, and ensure consistent terminology worldwide. Furthermore, consumer awareness and digital literacy are essential for a meaningful change.

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Advertisement Analysis Competition, 1st Place