The National Advertising Division (“NAD”) issued a new decision with helpful guidance for advertisers making performance claims about skincare products. NAD’s review of advertiser SolaWave’s substantiation for a wide range of claims was much more than “skin deep.” Unfortunately for SolaWave, its substantiation failed the test. NAD’s decision was the result of its routine monitoring function. While many NAD decisions are the result of competitor challenges, NAD can also open challenges on its own.