Twiish

Being a teenager is hard – and acne can make it harder.

Enter Twiish, a company run by a beauty editor and her teenage daughter that claims its Clear Skin Bundle is “the perfect kit for teenagers struggling with breakouts and who are new to skin care.”

The $44 bundle consists of a facial cleanser called Peachy Clean and a “zit spot treatment” called Zit Ain’t Cute that the company claims prevents breakouts. Twiish attributes the benefits of both products to its “hero ingredient” colloidal silver.

“There’s no denying that our hero ingredient is colloidal silver,” the company said in an Instagram post earlier this month. “Despite its incredible skin benefits, it kind of flies under-the-radar, but we’re here to change that.”

In fact, regulators have had a lot to say about colloidal silver.

The FDA, for example, has warned that colloidal silver isn’t safe or effective for treating any disease or condition. And when it comes to claims to treat acne and/or breakouts, the FDA has long held that such statements are drug claims requiring its approval, which Twiish does not have.

Yet this has not stopped Twiish from marketing its colloidal silver products as a safe and effective treatment for acne and breakouts.

The company is also currently running an “acne awareness month special” on its website for 20 percent off Zit Ain’t Cute. And the Clear Skin Bundle product page features customer reviews saying the company’s products helped clear up most of their acne or even got rid of their acne.

If you’re wondering if Twiish is responsible for what its customers say, the answer is yes, if the company uses the reviews in its marketing materials.

According to the FTC’s Health Products Compliance Guidance, “[A]dvertisers should not make claims through consumer testimonials … that would be deceptive or couldn’t be substantiated if the advertiser made them directly.”

TINA.org isn’t the only one taking a closer look at this new teen-focused skincare brand.

Recently, the National Advertising Division, the ad industry’s self-regulatory body, also spotted some issues with the company’s marketing.

NAD determined that Twiish implied that its products had been tested on and are safe for adolescent skin. But NAD could not confirm that the company’s products had been tested on young people’s skin and found to be safe because Twiish never responded to its inquiry.

NAD also found Twiish influencers promoting the company’s products without sufficiently disclosing their material connections with the company, which is a violation of the FTC’s Endorsement Guides.

After the company failed to respond to its inquiry, NAD referred both issues to the FTC for further review.

Twiish did not respond to a TINA.org request for comment.

Twiish isn’t the first “teen skincare” company whose marketing has come under fire. In 2014, TINA.org exposed Willagirl’s “no junk” claim after finding that the company’s products, which were marketed to girls ages 7 to 18, contained a number of problematic ingredients. After TINA.org alerted Willagirl to its findings, the company removed claims that its products are “all-natural” and “safe for sensitive skin.”

Find more of our coverage on skincare products here.