From Aveeno to L’Oreal, a Campaign investigation reveals how global giants are bypassing FDA laws to chase livestream revenue, triggering dozens of ‘red flag’ compliance violations in single sessions.
“If you have eczema, itchy skin, psoriasis, skin asthma, atopic dermatitis, keratosis pilaris, this one really, really helps.”
This bold claim made during a recent livestream in the Philippines for skincare brand Aveeno was just one of 75 instances of red flag (critical) compliance infringements in a single livestream by the brand.
The compliance breaches were identified by Campaign Asia using Stickler, a live commerce platform that works with brands and agencies to record and monitor livestreams. The platform has developed a compliance-check tool that is trained to check the language used in livestreams against local FDA-equivalent regulations to identify any compliance infringements.
During the livestream, the host repeatedly marketed cosmetic products as medical treatments for chronic skin diseases, which triggers an automatic legal reclassification from a ‘Cosmetic’ to a ‘Drug’ under Philippine FDA and ASEAN regulations. “It will soothe instantly the dryness, the itchiness, the redness, flakiness, itchiness…” the host said.
Under Philippine FDA and ASEAN regulations, making claims of “treatments” and “cures” triggers an automatic legal reclassification of a product from ‘cosmetic’ to ‘drug’—a designation that carries far stricter requirements for digital marketing and promotional permits.
Campaign contacted Aveeno regarding multiple compliance violations, to which corporate communications at parent Kenvue responded: “Aveeno Philippines strictly adheres to ASEAN and FDA Philippines regulations and guidelines. We remain cooperative to address concerns raised by the relevant authorities.”
The response is notable given that in November 2024, the Philippines FDA warned consumers not to buy or use the unauthorised cosmetic Aveeno Baby Eczema Therapy Moisturising Cream. The product was withdrawn because its name included “eczema,” suggesting a medical claim. It was later renamed to meet local cosmetic rules.
A pattern across markets
Aveeno’s livestreaming compliance breaches are not an isolated case. Campaign has found that compliance infringements are being identified across multiple markets during livestreams, each with its own regulatory regime, ranging from stricter to more relaxed.
It comes at a time when livestreaming is booming across APAC, where the region dominated global revenues at around $900 billion in 2024—driven overwhelmingly by China’s $800 billion, with Douyin alone generating $490 billion GMV and platforms like Taobao Live, Pinduoduo, and Kuaishou adding massive scale. Southeast Asia and India are also growing rapidly. However, the rapid rise of live commerce is outpacing compliance, governance, and responsibility, exposing global brands to real and immediate risk. As brands rush to in-house livestream operations to drive profitability, few are asking the more fundamental questions, what laws apply to live commerce and are we operating within the law?
“For brands, live commerce is a performance goldmine but also a compliance minefield,” says Shufen Goh, president, APAC at Mediasense. “Treating compliance as a secondary consideration exposes brands to fines, wasted content investment, media inefficiencies, and loss of consumer trust.”
Goh adds that compliance should be a foundational pillar, not an afterthought, in livestream commerce. “With content being spontaneous, visible, and fast-moving, brands need clear frameworks that embed governance across planning, scripting, and live execution. This means setting checkpoints, guiding influencers and brand ambassadors on responsible communication, anticipating regulatory risks, and enabling real-time monitoring.”
As livestreaming grows beyond China, regulators in Southeast Asia are tightening oversight of the channel. In Vietnam, new rules effective July 2026 require platforms to keep video and static ad records for three years, hold brands, hosts and platforms liable for claims, and prohibit cosmetics from being portrayed as medical treatments; livestream hosts are also now treated as ‘advertising conveyors’ and share legal responsibility for claims. In Thailand, brands face longer-tail liability through digital-trail rules that can preserve evidence for five to 10 years, while a January 2026 contract notification means exaggerated livestream claims can now be treated as contractual breaches, giving consumers a route to refunds and damages. The Thai FDA has also removed ignorance as a defence, meaning brands can be strictly liable if livestream claims imply therapeutic or medical benefits (mis-selling a cosmetic as a drug).
In another example, Campaign found that skincare brand Glad2Glow while operating livestreams in Indonesia, made multiple “absolute” claims—promising that a product can permanently change a physical condition or “eradicate” a problem.
A host claimed in one stream for Glad2Glow, quote: “Can also help brighten and help treat the acne. Can help ensure wrinkles on your face [are treated] down to the roots.” This was followed by similar claims of products being able to eradicate a problem.
“Anyway, whatever problems on your face we help exterminate down to the roots. Be it breakouts, black spots, acne, comedones, dull skin.” One host said.
Using prohibited language that suggests “treating” disease or “eradicating” issues to the root, is strictly forbidden by BPOM (Indonesian FDA). There were multiple instances where terms like “treating” and “eradicating to the roots” were used during Glad2Glow’s livestreams. Even claims of “removing scars” or promising permanent cures for severe acne were identified.
Such claims move the product from the realm of ‘appearance enhancement’ (cosmetic) to ‘physiological modification’ (therapeutic), which could expose the brand to immediate regulatory action.
The same pattern of ‘medicalisation’ was observed in P&G’s livestreams in Indonesia, where cosmetic hair and skincare products were positioned as clinical treatments for serious scalp conditions. In one session, a host responded to a viewer’s medical query by recommending a shampoo to treat diagnosed diseases. Quote: “Especially also for recommendations from the doctor… I have psoriasis on scalp, I have dermatitis on my scalp… Use the etalase 54 57 [Argan Oil product]… it can help reduce the spread of psoriasis or dermatitis.”
This explicitly violates BPOM regulations in Indonesia, which prohibit cosmetics from claiming to treat or reduce the spread of named diseases. Campaign’s audit of the streams also flagged high-severity violations where shampoos were marketed to ‘fight lice’ (kutu) and ‘dandruff’ (ketombe), as medical conditions rather than cosmetic concerns.
While majority of livestreaming happens on TikTok, the same compliance breaches were also observed on Shopee. A compliance audit of an Aveeno livestream on Shopee Indonesia flagged dozens of critical ‘red light’ violations under BPOM Regulation No. 18/2024, including repeated claims that products “menyembuhkan” (cure/heal) eczema (“eksim”), dermatitis, inflammation (“peradangan”), and scars (“bekas luka”).
Hosts positioned Aveeno moisturisers, like Skin Relief and Dermexa lines, as treatments for named diseases and even advised pregnant viewers on preventing stretch marks through physiological modification, illegally elevating cosmetics to drug status. With 95-100% transcript confidence on prohibited phrases, this highlights how brands risk the same reclassification pitfalls across e-commerce platforms.
Giants like L’Oreal and Fenty Beauty also not immune to live-streaming pitfalls
The issue is not confined to emerging markets, it is also prevalent in the UK, where L’Oreal Paris livestreams frequently crossed into ‘red light’ territory by claiming physiological modifications.
Under UK Cosmetics Regulation (EC) No 1223/2009, a product cannot legally claim to ‘restore, correct, or modify’ physiological functions. Yet, hosts were recorded claiming that the Revitalift Laser Serum could, quote: “Relax your features” or put the skin into a “relaxed state” to smooth expression lines.
Such phrasing mimics the mechanism of botox and implies a pharmacological action on muscles or nerves, a claim strictly prohibited for topical cosmetics in the UK.
The regulatory risks are perhaps most pronounced in the US, where the boundary between cosmetics and drugs is strictly policed by the US FDA and FTC.
One example is Truly Beauty, a brand that has already faced significant regulatory action. In 2019, the FTC sanctioned the company (then operating as ‘Truly Organic Inc.’) with a $1.76 million judgment for deceptive marketing practices.
Despite this history, recent audits of their livestreams identified a staggering 89 ‘red flag’ (critical) compliance violations in a single session. The host repeatedly bypassed cosmetic boundaries by claiming products could treat specific medical conditions and prevent infections. * Quote: ‘vanilla is anti-inflammatory antimicrobial… peptides stimulate that collagen production’. * Quote: ‘[If you are] prone to UTIs, yeast infections… get rid of that fungi-forming bacteria and microorganisms’.
By promising that products can ‘get rid of’ conditions like Keratosis Pilaris (KP) and ‘strawberry legs’ rather than merely improving their appearance, the brand effectively reclassifies its products as unapproved new drugs. Promising to physically alter the body, places the brand back under the same heightened scrutiny that led to its previous million-dollar settlement.
Even established global giants like Fenty Beauty are not immune to these livestreaming pitfalls. While Fenty’s official policy strictly prohibits language implying products can ‘treat, cure, heal, or mitigate specific diseases,’ the live environment often tells a different story. In one audit, the host repeatedly claimed products could ‘heal’ the skin and explicitly recommended them for Eczema, a clear ‘red flag’ violation of US FDA guidelines.
“This is gonna heal you and protect your skin. It actually will help to heal really dry skin… like great on the feet also love it for my cuticles…” the host said in a livestream for Fenty Beauty.
Most of the breaches were identified with 90% transcript confidence, meaning the language used was clear, unambiguous, and in violation of local laws. In the Aveeno case alone, the frequency of violations was extremely high, with Campaign identifying 75 instances of ‘red flag’ (critical) violations in a single session, with the host assuming a pseudo-medical advisory role.
Far from being just the odd off-the-cuff remark made by hosts, the streams show that the same non-compliant statements are repeated almost verbatim, suggesting they may be scripted rather than improvised. It’s unclear whether hosts create the scripts themselves or are given specific lines, but the repetition indicates that infringements systematic, not just accidental ad-libbing.
However, many should already be aware of their responsibilities. In the US, the FTC began sending notices to influencers and marketers in 2023, reminding them of #ad disclosure rules under 16 CFR Part 255, with penalties up to $52,430 per violation.
Campaign reached out to all brands whose livestreams were monitored, but they did not respond to requests for a statement on the compliance breaches flagged.
Platform liability and the ‘China precedent’
While many audited livestreams ran on TikTok, similar breaches appeared on Shopee. In terms of compliance, TikTok positions itself as a delivery channel and does not assume accountability for what is said in streams; brands, who staff many of the streams directly or through agencies, assume this liability. While TikTok retains moderation powers and can suspend accounts, brands bear most regulatory/commercial fallout (although with Thailand and Vietnams new laws this may have shifted slightly.)
TikTok Shop/TikTok Live terms typically require brands to indemnify the platform against user-generated claims and ensure affiliate content complies with local laws, shifting primary liability to advertisers. Affiliates promoting products on their own channels, and hosts appearing on brand channels, also tend not to be held accountable. In the event of infringements, it is the brand that faces regulatory and commercial consequences.
In China, TikTok (Douyin) has banned brands that breach regulations. Douyin routinely shuts down brand stores and bans accounts for regulatory breaches like false advertising, counterfeit sales, or illegal promotions, rather than just fining, part of a strict ecosystem cleanup enforced with regulators like SAMR. With similar regulatory environments emerging globally, this is a ticking time bomb for major brands.
Campaign presented some of the findings from the investigation to TikTok and a spokesperson responded: “We have strict policies in place that prohibit the misleading promotion of products on our platform in compliance with local laws and regulations where TikTok Shop operates.”
A significant risk for brands is the gap between legislation and platform enforcement. If brands go live on platforms like Shopee and their hosts break the rules, it is not down to the platform to police or enforce the law, and so the brand is liable for what their host says.
The tightening global regulatory net
Ewan Lusty, a partner at regulatory advisory Flint Global, points out that China’s maturity in this space means its regulations often set the precedent for the rest of the region. He highlights new January 2026 guidelines from the Cyberspace Administration of China that ban impersonating AI promotions and mandate human review for platform complaints. Other markets are moving just as fast. Singapore’s consumer commission (CCS) recently issued guidance requiring all claims to be “truthful, clear, meaningful, and evidence-based,” while Vietnam will soon require livestreamers to verify their identities via VNeID and expressly prohibits false statements during streams.
“Overall, authorities in Asia-Pacific are adopting a tougher stance on e-commerce, including livestreaming,” says Lusty. “Key provisions across the region include bans or guidelines on misleading claims, mandatory identity verification for sellers, and new restrictions on the role of AI in livestreams.”
China now holds influencers and livestream hosts jointly liable for unsubstantiated claims, and Southeast Asian regulators are watching closely. The direction of travel across the region is clear, and it is only going to tighten. Brands that build governance infrastructure now will be better positioned than those who wait to be forced into it.
But questions remain around how much or how little brands care or even know about these compliance breaches.
One Campaign source, who has requested to remain anonymous, said that when reports showing multiple compliance infringements were presented to one brand’s data and insights team, the reaction was essentially: “That’s not my problem; I just need the performance data.” This illustrates a profound accountability gap, with sales, marketing and analytics teams focused on GMV and KPIs, while no one clearly owns compliance risk for live commerce.
Leela Nair, managing director APAC-MEA ebiquity plc, says that compliance needs to be a pre-flight obligation, not a post-campaign audit. “Most of our clients conduct compliance and performance audits with us at least once a year, and that is a strong foundation. But for livestream commerce, the pace and informality of the format demands more embedded, ongoing oversight.”
Nair adds that contracts must address disclosure requirements clearly, and that measurement frameworks need to capture quality alongside volume.
“The brands getting this right are not treating compliance as a separate workstream,” says Nair. “They are building it into how they buy and measure media from the outset.”
The accountability gap
TikTok Shop Partners (TSPs) that originally just set up TikTok shops have moved into managing livestreams and are scaling rapidly across Southeast Asia, in some cases growing 40–500% year on year as they onboard more brands. At one end of the spectrum, some large global brands hand everything to the TSP, monitoring only GMV at the end of the month.
An anonymous source has told Campaign that a founder of a regional TSP, when shown evidence of infringements, responded along the lines of “we all do it, don’t we?”, indicating that non-compliant claims are seen as commonplace and not something they feel compelled to change. This reinforces the picture of an ecosystem optimised almost entirely for sales and growth, with minimal appetite to address legal or ethical risk until forced to do so. The lack of ownership highlights how unprepared many global brands are for what’s coming.
Industry insiders suggest we may soon see a large TikTok Shop partner permanently banned, making this an inflection point for global e-commerce accountability. The wider implications stretch far beyond Asia, affecting major cosmetic houses headquartered in France, and multinationals active in the US and Europe. In markets in Southeast Asia, where TikTok Shop represents over 20% of all ecommerce with higher penetration in certain demographics, a ban for a brand could be a significant blow to a market’s viability.
Fionn Hyndman, founder of Stickler, which provided compliance data for this investigation added: “Every major channel reaches the point where governance catches up with growth. Live commerce is at that point now. The industry has not shown that it can regulate itself, and when regulators step in the stakes become more significant. Compliance can no longer sit at the edges of the livestream operation. The channel needs to operate with the same professionalism and brand scrutiny that brands use in all advertising. The standards have to be built into the way brands plan, train, monitor and manage the entire channel from hosts to retailers, affiliates to influencers. Live commerce is clearly here to stay and is one of the fastest growth channels in retail, so the question for brands is no longer whether they participate, but whether they can participate responsibly.”
For global brands, the window for “accidental” non-compliance is closing. Lusty stresses that proactive action is now essential to limit regulatory and reputational risks. “Global brands should track closely the evolving regulatory landscape and put in place a robust compliance and regulatory affairs programme on livestreaming,” he says. This includes mapping obligations in different markets and ensuring compliance practices are consistently followed, moving live commerce from a wild-west sales channel to a disciplined, governed pillar of global retail.
This story first appeared on Campaign Asia-Pacific.