Most people assume the phrase is regulated. It isn’t, at least not in the way shoppers imagine. In the cosmetics aisle, “clinically proven” can describe a rigorous trial with a control group and blinded assessment. It can also describe a questionnaire sent to forty people who received free products.
Evan Zhao, co-founder and CEO of RE:YOU, has spent a lot of time looking at how that gap gets exploited. His view of the hair category is blunt: a meaningful share of its marketing exists to convert hope into subscription revenue, and the science-sounding language is the conversion mechanism.
A few patterns are worth knowing before you buy anything.
Percentages without denominators. A claim like “94% of users noticed improvement” tells you almost nothing on its own. Improvement measured how? By whom? Over what period? Against what baseline? Self-reported satisfaction surveys are common in this category and are frequently presented in the visual language of clinical data — charts, decimal points, a small asterisk leading to fine print that describes a consumer perception study.
Sample sizes you’re not shown. Genuine trials publish their participant counts prominently because the number supports the claim. When the count is hard to find, that’s usually deliberate.
Before-and-after photography. This is the least regulated and most persuasive tool in the category. Lighting direction, hair styling, part placement, camera distance, and whether the hair is wet or dry can all produce a dramatic apparent difference with no biological change underneath. Zhao’s position is that photographic evidence should be treated as marketing until proven otherwise.
Ingredient theater. Proprietary complexes with molecular-sounding names, listed at concentrations the label never discloses. The ingredients may be real and may even be interesting. Whether it’s present at a level that does anything is a separate question, and one the packaging is designed not to raise.
“Dermatologist tested.” Tested for what? The phrase most often means a safety or irritation assessment, which says nothing about whether the product grows hair.
Zhao co-founded RE:YOU as a direct response to all of this. The company positions itself as a biotech haircare brand built on molecular research, with the evidence work treated as the actual product rather than the sales copy. More at getreyou.com.
His argument is that the category’s dishonesty isn’t just an ethical problem for the brands doing it. It’s a structural problem for everyone else, because it trains consumers to discount all claims equally. When every product on the shelf says the same thing, the ones with real evidence behind them have no way to signal it.
That’s the part Zhao seems most interested in changing, and it’s harder than it sounds. Honest claims are less exciting than dishonest ones, take longer to substantiate, and cost more to produce.
The practical advice for anyone shopping: read the asterisk. The fine print is where the actual claim lives, and it’s usually much smaller than the one on the front.