United Kingdom · CAP Code 3.7 · disclaimers

“Results may vary” disclaimers vs CAP substantiation — what the footnote does not fix

Teams often add a small-print “results may vary” or “individual results may differ” line beneath before-and-after photos or percentage claims. Under UK CAP practice, that disclaimer rarely replaces rule 3.7 substantiation for the headline claim consumers actually read. This guide explains the inventory habit — not ASA clearance.

Not ASA clearance. Not legal advice. CiteBefore inventories claims and evidence columns; the ASA decides complaints.

Why disclaimers usually fail alone

CAP’s substantiation AdviceOnline and general qualifications AdviceOnline stress:

The ASA assesses the likely interpretation of the ad as a whole — headline, imagery, and footnote together.
Qualifications must be clear and prominent. A grey 8px footer under a bold “Lose 10kg in 4 weeks” hero rarely qualifies the main claim.
Objective efficacy claims still need objective evidence before publication — a variance disclaimer is not a substitute for a trial pack.
Contradictions between headline and footnote can fail rule 3.9 (substantiation vs presentation).

Common landing-page patterns to inventory

Disclaimer patterns — inventory rows, not clearance verdicts
On-page pattern	Headline claim	Inventory question
Before/after photos + “results may vary”	Implied efficacy or transformation	Is the visual itself a claim? Hold evidence for the stated outcome, not just the disclaimer.
“Up to 50% faster*” + buried asterisk	Performance statistic	Does the asterisk link to a visible qualification? Hold calculation for the “up to” figure.
Testimonial quote + “not typical” footer	Objective performance inside the quote	Inventory the objective line under 3.7 — testimonials alone rarely substantiate it. See testimonials guide.
“Clinically proven” + “In a study of 12 participants”	Clinical efficacy	Does the study match product, endpoint, and population? See clinically proven checklist.

Working habit — claim first, disclaimer second

Inventory the headline and hero imagery as standalone claims — what would a consumer take away without scrolling?
Mark evidence held or gap for each objective claim under CAP 3.7.
Then read the disclaimer — does it genuinely qualify the claim, or merely hope to deflect liability?
Re-scan after edits — same URL, new claim set. See before-and-after URL guide.

Try it on your URL. CiteBefore’s free scan flags high-risk claim/disclaimer pairs. The £29 register is the file-ready inventory with Evidence columns.

What CiteBefore does — and does not do

Not ASA clearance that a disclaimer makes a page compliant.
Not legal advice on qualification placement or font size.
Inventories headline claims, footnotes, and imagery on a live URL — you decide whether evidence is held.

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FAQ

Does “results may vary” mean I do not need substantiation?

Usually no. Under CAP, objective claims still need documentary evidence held before publication. A small-print variance line rarely replaces substantiation for the headline or hero imagery consumers are likely to read.

Where should qualifications appear on a landing page?

CAP expects qualifications to be clear and prominent enough that consumers see them alongside the claim they modify. A buried footer under a bold hero is often insufficient — inventory the layout, not just the text.

Related guides

Informational only. Not ASA clearance. Last reviewed September 2026.