Advertising Claims in Singapore: What You Can and Cannot Say in 2026

Every advertisement makes a claim — whether it is an explicit statement about product performance, an implied promise of quality, or a visual representation of results. In Singapore, every one of those claims must be substantiated before publication. The Singapore Code of Advertising Practice (SCAP), administered by the Advertising Standards Authority of Singapore (ASAS), requires advertisers to hold evidence supporting their claims before running any advertisement, not after a complaint is lodged.

The stakes are real. ASAS can compel advertisers to withdraw non-compliant advertisements, and serious cases can be referred to the Competition and Consumer Commission of Singapore (CCCS) for statutory enforcement under the Consumer Protection (Fair Trading) Act. Beyond regulatory consequences, misleading claims erode consumer trust and damage your brand’s credibility in a market where word-of-mouth and online reviews carry enormous weight.

This guide covers the substantiation requirements for different types of advertising claims commonly used by Singapore businesses. Whether you are writing copy for Google Ads, creating social media content, or developing claims for product packaging, understanding these rules will help you create advertisements that are both compelling and compliant.

Substantiation Requirements

The fundamental rule of advertising claims in Singapore is simple: if you say it, you must be able to prove it. The SCAP requires advertisers to hold documentary evidence to support all claims — whether direct or implied — before an advertisement is published.

Types of Claims

Claims fall into several categories, each with different substantiation requirements:

Objective claims — factual statements that can be measured or verified (e.g., “removes 99.9% of bacteria”). These require scientific evidence, test results, or verified data.
Subjective claims — matters of opinion that cannot be objectively measured (e.g., “the tastiest coffee in town”). These have more leeway but must not be misleading in context.
Comparative claims — statements comparing your product or service to competitors. These require evidence demonstrating the comparison is fair, accurate, and based on verifiable facts.
Implied claims — claims suggested by images, layout, or context rather than explicit words. These are held to the same standard as explicit claims.

What Counts as Adequate Substantiation

The level of evidence required depends on the nature of the claim. As a general guide:

Performance claims should be supported by independent testing, scientific studies, or verifiable data
Statistical claims must be based on robust, properly conducted research with adequate sample sizes
Survey-based claims (e.g., “9 out of 10 dentists recommend”) must disclose the methodology, sample size, and any limitations
Expert endorsements must come from genuinely qualified individuals whose expertise is relevant to the claim
Customer testimonials must be genuine and represent typical, not exceptional, experiences

If you are developing claims for content marketing assets such as case studies or whitepapers, the same substantiation standards apply whenever you make factual assertions about your products or services.

Health and Wellness Claims

Health claims are among the most heavily scrutinised in Singapore’s advertising landscape. They are regulated not only by the SCAP but also by the Medicines Act, the Health Products Act, and guidelines issued by the Health Sciences Authority (HSA).

What Constitutes a Health Claim

A health claim is any statement that suggests a product can prevent, treat, cure, or alleviate a medical condition, or that it provides a specific health benefit. This includes claims about supplements, food products, skincare, fitness products, and wellness services. Even vague claims like “boosts immunity” or “detoxifies your body” are considered health claims requiring substantiation.

Rules for Health Claims

No therapeutic claims without approval — products cannot claim to treat, cure, or prevent diseases unless they are registered as medicines with the HSA
Scientific evidence required — health benefit claims must be supported by credible scientific evidence, ideally peer-reviewed studies
No misleading implications — before-and-after images, personal testimonials about health outcomes, and implied medical endorsements must not mislead consumers about what the product can achieve
Qualification of claims — general health benefit claims should include appropriate qualifiers (e.g., “as part of a balanced diet” or “results may vary”)
No exploitation of fear — advertisements must not exploit consumers’ fear of illness or health conditions to promote products

Practical Example

A supplement brand advertising in Singapore can say “contains Vitamin C, which contributes to normal immune function” (a permitted nutrition claim) but cannot say “prevents colds and flu” (a therapeutic claim that would require HSA registration as a medicine). The distinction is critical, and getting it wrong can result in both ASAS complaints and HSA enforcement action.

Environmental and Green Claims

Environmental claims — also known as green claims — have come under increasing scrutiny globally and in Singapore. As consumers become more environmentally conscious, businesses are eager to promote their sustainability credentials. But vague or unsubstantiated green claims, known as “greenwashing,” are drawing regulatory attention.

Common Green Claims and Their Requirements

“Eco-friendly” or “green” — these are extremely broad claims that require comprehensive evidence. Unless your product or service is genuinely environmentally beneficial across its entire lifecycle, avoid these terms.
“Recyclable” — the product or packaging must actually be recyclable in Singapore’s waste management infrastructure. A product labelled recyclable that cannot be recycled locally is misleading.
“Carbon neutral” — must be substantiated with verified carbon accounting and genuine offset programmes. The methodology should be transparent and based on recognised standards.
“Sustainable” — requires evidence of sustainable practices across the supply chain. Partial sustainability (e.g., one sustainable ingredient in an otherwise unsustainable product) does not justify a blanket “sustainable” claim.
“Biodegradable” — the product must biodegrade under normal disposal conditions within a reasonable timeframe. Industrial composting conditions do not count if the product will end up in a landfill.

Best Practices for Green Claims

Be specific rather than vague. Instead of “eco-friendly packaging,” say “packaging made from 80% post-consumer recycled materials.” Specific, verifiable claims are less likely to attract complaints and more likely to resonate with environmentally conscious consumers in Singapore. If you are building green messaging into your social media marketing, ensure every claim can be backed with documentation.

Price Claims and Promotions

Price claims are a frequent source of ASAS complaints. The rules are straightforward: any price claim must be accurate, clear, and not misleading.

Key Rules for Price Claims

Advertised prices must include GST — the price shown in the advertisement must be the total price the consumer will pay, inclusive of 9% GST (as of 2026). Quoting prices before GST in consumer-facing advertisements is misleading.
“Was/Now” pricing — if you show a previous price alongside a current price to indicate a discount, the previous price must have been genuinely charged for a reasonable period. Inflating a “was” price to make a discount appear larger is a breach of the Code.
“Lowest price” or “cheapest” — superlative price claims must be verifiable. You must be able to demonstrate that your price is genuinely the lowest in the relevant market at the time of the advertisement.
Hidden charges — all mandatory fees, surcharges, and additional costs must be disclosed in the advertisement. A headline price that excludes significant mandatory charges is misleading.
Limited availability — if the advertised price is only available for a limited number of items or a limited period, this must be clearly stated.

Sale and Promotion Claims

Advertisements for sales and promotions must accurately represent the offer. “Up to 70% off” is only acceptable if a meaningful proportion of items are genuinely discounted by close to 70% — not just one item in the entire range. Terms and conditions of promotions must be clearly communicated and not hidden in fine print that contradicts the headline offer.

Free Offers and Gifts

The word “free” is one of the most powerful — and most regulated — terms in advertising. The SCAP has specific rules governing its use.

When “Free” Really Means Free

An offer can only be described as “free” if the consumer does not have to pay anything — including postage, packaging, handling charges, or any other cost — beyond the minimum necessary to respond to the offer and collect the item. If any cost is involved, it must be clearly stated alongside the word “free.”

Conditional Free Offers

Free offers that require a purchase (e.g., “buy one, get one free” or “free gift with purchase of SGD 100 or more”) must clearly state the conditions. The price of the product being purchased must not have been inflated to recover the cost of the free item. If a “buy one, get one free” offer is effectively just a 50% discount on two items, calling it “free” is misleading if the original price has been inflated.

Free Trials

Free trial offers must clearly disclose what happens when the trial ends. If the customer will be automatically charged or subscribed after the trial period, this must be prominently communicated — not buried in terms and conditions. The cancellation process must be straightforward and clearly explained.

If you are running free trial promotions through email marketing, ensure the terms are disclosed in the email itself, not just on a linked landing page that the subscriber might not read.

Guarantees and Warranties

Guarantee and warranty claims in advertisements must be clear, honest, and deliverable. Vague promises like “satisfaction guaranteed” or “money-back guarantee” are only acceptable if you genuinely honour them without unreasonable conditions.

Rules for Guarantee Claims

The full terms of the guarantee must be available to the consumer before purchase
Any conditions, limitations, or exclusions must be clearly stated in the advertisement or easily accessible
The process for making a claim under the guarantee must be straightforward and clearly communicated
Guarantees must not be used to imply a level of protection greater than what is actually provided
“Lifetime guarantee” must specify whose lifetime is being referred to — the product’s expected lifespan or the consumer’s lifetime

Satisfaction Guarantees

If you advertise a “satisfaction guarantee” or “money-back guarantee,” you must honour refund requests without imposing unreasonable hurdles. Requiring customers to jump through excessive hoops — filling out lengthy forms, returning products at their own expense, waiting months for a refund — undermines the guarantee claim and can result in ASAS complaints and CCCS scrutiny.

Using Disclaimers Effectively

Disclaimers are a necessary part of many advertisements, but they are not a licence to mislead. A disclaimer cannot be used to contradict the main message of an advertisement — if the headline says one thing and the fine print says the opposite, the advertisement is misleading regardless of the disclaimer.

Best Practices for Disclaimers

Visibility — disclaimers must be legible and presented in a font size, colour, and position that makes them noticeable. A disclaimer in 6-point grey text on a white background does not meet this standard.
Proximity — disclaimers should be close to the claim they qualify. A disclaimer on a separate page or at the bottom of a long document is less effective than one placed directly below the relevant claim.
Clarity — use plain language. Legal jargon that consumers cannot reasonably understand does not fulfil the purpose of a disclaimer.
Consistency — the disclaimer must not contradict the main message. If your headline says “no hidden fees” and your disclaimer lists additional fees, the advertisement is misleading.

Digital Advertising Disclaimers

In digital advertising, space constraints often make disclaimers challenging. For Google Ads and social media ads with character limits, essential disclaimers should be included in the ad itself or clearly visible on the landing page before any conversion action. “Terms and conditions apply” is not an adequate disclaimer — the consumer needs to understand the key conditions before engaging with the offer.

For website landing pages, ensure disclaimers are visible without requiring the user to scroll extensively or click through multiple pages. Pop-up disclaimers that appear only after a user has committed to an action are particularly problematic.

Frequently Asked Questions

What happens if I cannot substantiate a claim after an ASAS complaint?

If you cannot provide adequate evidence to support a claim that has been challenged, ASAS will likely uphold the complaint and require you to withdraw or amend the advertisement. The decision will be published, creating a public record of the breach. In serious cases, ASAS may refer the matter to the CCCS for possible enforcement under the Consumer Protection (Fair Trading) Act, which can result in injunctions and other statutory remedies. The key lesson is to substantiate claims before publishing, not after a complaint forces your hand.

Can I use customer testimonials as evidence for advertising claims?

Customer testimonials can support claims, but they must be genuine, verifiable, and representative of typical outcomes. A single exceptional testimonial does not substantiate a general claim. If your advertisement implies that all customers will experience the same results, you need broader evidence — such as survey data or aggregated results — to support that implication. Always obtain written permission to use testimonials, and never edit them in ways that change their meaning.

Are there special rules for advertising claims about Singapore-made products?

Yes. Claims about a product being “made in Singapore,” “Singapore-made,” or “Product of Singapore” must be accurate. The product must have undergone substantial transformation in Singapore — simply packaging or labelling a product in Singapore does not qualify. These claims are governed by customs regulations and the SCAP’s truthfulness requirements. Misleading origin claims can also trigger enforcement by Singapore Customs.

How do I handle advertising claims for services rather than physical products?

Service claims follow the same substantiation principles as product claims. If you claim that your service delivers specific results (e.g., “we increase website traffic by 200%”), you need evidence to support that claim — typically in the form of case studies, client data, or independently verified performance records. Avoid presenting best-case results as typical outcomes, and include appropriate qualifiers where necessary. Service-based businesses running SEO or marketing services should be particularly careful with performance guarantees.

What constitutes misleading imagery in Singapore advertising?

Images in advertisements must accurately represent the product or service being sold. This includes food photography (the product must closely resemble what the consumer will receive), beauty products (before-and-after images must not be digitally manipulated to exaggerate results), and property advertisements (images must represent the actual property or development, not idealised renders that bear little resemblance to reality). The overall impression created by the imagery is what matters — even if the text is accurate, misleading images can breach the Code.

Do these rules apply to business-to-business (B2B) advertising?

The SCAP primarily governs consumer-facing advertising, but B2B advertisements are not exempt from truthfulness and substantiation requirements. The Consumer Protection (Fair Trading) Act applies to consumer transactions, so B2B-specific advertising faces less regulatory scrutiny. However, misleading B2B claims can still result in legal liability under contract law and tort law. Best practice is to apply the same substantiation standards to B2B advertising as you would to consumer advertising.

Advertising Claims in Singapore: What You Can and Cannot Say in 2026