CCCS Raises Concerns with OSIM’s Product Information Transparency and Pricing

(View Media Release in PDF)

1. OSIM International Pte. Ltd. (“OSIM”) has provided an undertaking to the Competition and Consumer Commission of Singapore (“CCCS”) to improve transparency in its product information after CCCS raised concerns about some of OSIM’s business practices, including product endorsement, product standards, suitability for specific consumers, and pricing.

2. The concerns raised by CCCS regarding OSIM’s business practices were:

a) The use of “Stanford Medicine” logo in promotional materials for their “uLove3 Well-Being Chair”^[1] which could mislead consumers into thinking that the product was endorsed by institutions that were associated with this logo^[2], when in fact, the technology used in OSIM’s product was endorsed only by a medical consultant who had lectured at the Stanford University School of Medicine.

b) Indicating on its website that some products were “ Certified”^[3], where “” is generally understood to refer to Conformité Européenne. This could potentially mislead consumers into thinking the products were certified by an authority, when the “” mark is a self-declared mark by manufacturers who assert that their product conforms with relevant European legal requirements. There is no certification processes by authorities associated with this mark.

c) Lack of pre-purchase disclosure about product suitability for individuals with specific health or medical conditions.^[4] Such information was only available in the product manuals contained inside the packaging. Coupled with OSIM’s policy to preclude refunds once the packaging was opened, consumers who were affected might not be able to obtain refunds even though they only found out about the unsuitability of the product after they had made their purchase.^[5]

d) OSIM’s ‘usual’ prices, presented alongside promotional prices for several products were not genuinely ‘usual’ as they were not prices offered to retail customers for a significant period prior to the relevant promotion.^[6] This could mislead consumers about the actual discount they would enjoy.

3. OSIM has since taken the following steps to address the concerns raised by CCCS:

a) Removed “Stanford Medicine” logo from its promotional materials;

c) Provided greater disclosure of product suitability information on its website and instructed its sales representatives to remind customers about product suitability before purchase;^[7] and

d) Ensured that its promotions reflected actual discounts.

4. As part of the undertaking given to CCCS, OSIM also agreed to implement an internal compliance policy to ensure compliance with Singapore’s fair trading laws.

5. “CCCS combines rigorous enforcement with collaborative industry engagement to improve fair trading business practices. In this case, we acknowledge OSIM’s active response to address the concerns raised by CCCS and its commitment to improve its business practices. We encourage other businesses to review their practices to ensure that any representations they make are accurate, genuine, and include sufficient disclosure to reduce the risk of consumer disputes and enhance trust in the marketplace”, said CCCS’s Chief Executive, Mr. Alvin Koh.

Encl. Appendix

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About the Competition and Consumer Commission of Singapore

The Competition and Consumer Commission of Singapore (“CCCS”) is a statutory board of the Ministry of Trade and Industry. CCCS administers and enforces the Competition Act 2004 which empowers CCCS to investigate and adjudicate anti-competitive activities, issue directions to stop or prevent anti-competitive activities and impose financial penalties. CCCS is also the administering agency of the Consumer Protection (Fair Trading) Act 2003 or (“CPFTA”) which protects consumers against unfair trade practices in Singapore. Our mission is to make markets work well to create opportunities and choices for businesses and consumers in Singapore.

For more information, please visit www.cccs.gov.sg.

^[1] See Appendix for the screenshot of OSIM’s use of the “Stanford Medicine” logo on its website (https://sg.osim.com/en).

^[2] Stanford Medicine comprises the Stanford University School of Medicine, Stanford Health Care and Stanford Children’s Health.

^[4] The concerns apply for the following products: uPulse, uCozy, uDream, uThrone, uDivine V and uCrown. See Appendix for an example of a health warning from the product manual of uPulse.

^[5] CCCS received a complaint in 2021 of a customer who purchased an OSIM product only to realise that the product was not suitable for use after opening the packaging and reading the product manual. The complainant’s refund request was initially rejected as the package had been opened. OSIM eventually agreed to provide a refund to the complainant.

^[6] CCCS found that none of the “usual prices” presented for several of OSIM’s products for the period 1 January 2022 to 14 May 2023 were actually offered to consumers over the same period. Paragraph 3.3.3 of the CCCS’s Guidelines on Price Transparency states that “When suppliers offer a discount and/or make comparisons with a previous price to represent a price benefit, they should use a bona fide previous price to provide a basis for the price comparison so that consumers are not misled by the savings they may achieve from purchasing the discounted product/service”.

^[7] Specifically, OSIM added a “Product Usage Suitability” notice across all its product listings on its website and e-commerce channels. Within OSIM’s physical stores, OSIM included a disclaimer in the price cards for its displayed products to refer consumers to OSIM’s website for product usage suitability information and undertook to remind consumers on product suitability at the point of purchase.