The 12 most common ASC violations — and how to avoid them

Almost every rejection we see in pre-screening falls into one of twelve patterns. The good news is that means most rejections are preventable. The patterns are well-defined in the ASC Code and well- known to the screening committee. Once your team has internalised them, first-pass clearance rates jump.

This is the working list, ranked by how often we see each pattern.

1. Unsubstantiated No. 1 / leadership claims

"No. 1 in the Philippines," "the leading brand," "the country's favourite." Each of these triggers mandatory screening and requires 12 months of cumulative retail audit data — both volume and value — from an independent source. National claims require geographic coverage across North and Central Luzon, South Luzon, Visayas, and Mindanao plus key Metro Manila districts.

Fix: If you don't have 12 months of independent retail audit, don't write the claim. Use a softer parity claim ("Filipinos' choice," "trusted by families") and back it with the evidence you do have.

2. Absolute claims without three independent tests

Words like "100% effective," "guaranteed," "always," "sure," and "completely" trigger absolute-claim substantiation. The Code requires three separate, identical tests by an accredited third party at one-month intervals, following the same methodology. "Helps" does not let you circumvent this rule.

Fix: Soften to a quantified claim ("removes 99% of germs in lab conditions") with the single supporting test cited on screen, rather than an unsupported absolute.

3. Comparative claims without verifiable data

"Better than the leading brand," "more effective than the alternative," "tastes better than." Direct comparisons are allowed only in specific categories (automotive, consumer durables, airlines and shipping, musical instruments and entertainment equipment, mobile devices). Outside those, comparative claims must be indirect, qualified ("vs another brand" or "vs previous formulation"), and supported by third-party data.

Fix: Use indirect comparison with a clear qualifier and third-party research. Do not show competitor branding without consent. See our piece on when you can name a competitor in Philippine ads.

4. Health and efficacy claims beyond the FDA registration

The claim in the ad cannot exceed the claim in the Certificate of Product Registration. A product registered as a regular food cannot carry implied therapeutic benefits. A food supplement cannot make therapeutic claims — and must carry the standard "MAHALAGANG PAALALA" message in the format prescribed by FDA AO 2010-008.

Fix: Map every claim in the ad to a specific line in the CPR before the shoot. Stop matching the brief to the creative wish list; match it to the registration.

5. Missing or non-compliant generic name rendition

OTC drugs must show the generic name in a box, immediately above the brand name, in a font size larger than the brand name (per DOH AO 2016-008). For TVCs 30 seconds and longer, the generic name must be mentioned twice — once at first brand mention, once towards the end for at least one second. Audio ads must end with "[GENERIC NAME] is the generic name of [BRAND NAME]" and "If symptoms persist, consult your doctor."

Fix: Build the generic-name treatment into the storyboard, not the colour grade. Have the medical director sign before submission.

6. Implied health benefits in food and beverage ads

A child becoming alert after a milk drink, a senior walking with ease after a supplement, an athlete recovering after a sports drink. Even without spoken claims, these visuals carry an implied health benefit that the committee will substantiate. See our food & beverage guide for category specifics.

Fix: Either substantiate the implied benefit with clinical evidence or remove the visual cue.

7. Before / after without representative results

Skincare, weight loss, hair, dental, and cleaning categories rely on transformation visuals. Each comparison must cite the specific time elapsed between "before" and "after," show typical (not cherry-picked) results, and carry "results may vary" where relevant. See before/after rules for skincare and beauty ads.

8. Influencer paid partnerships without disclosure

Influencer content for products in must-screen categories or carrying must-screen claims is treated as advertising. Where the influencer is under contract, disclosure is required and the claims need third-party substantiation. Signed and notarized endorser certifications must be on file. See the disclosure rules for influencer ads.

9. Child talent without permits or in inappropriate contexts

Child performers need talent permits. The ad cannot show children alone in situations requiring adult supervision, cannot position children as pressuring parents to buy, and cannot encourage excessive eating, gluttony, or excessive drinking of non-alcoholic beverages. Foods classified as HFSS (high in fat, salt, or sugar) carry additional restrictions when targeted at children under 16.

10. Suggestive brand-name claims

A brand named "Real Juice" or "True-Milk" cannot use the suggestive name as a product claim unless the underlying claim is substantiated by evidence other than the brand name itself.

Fix: Substantiate the implied claim or restrict the ad to brand-as-name positioning rather than brand-as-claim.

11. Pre-emptive rights violations

Distinctive elements — slogans, layouts, music cues, sound effects, visual signatures — belong to the brand that used them first. The protection period is two years for non-competitive products and five years for competitive products. The committee and competitors both watch for this.

Fix: Pre-emptive-rights search before the creative is locked. Distinctive sound design and brand-asset review at concept stage.

12. Promotional ads without regulator permits

Sweepstakes, raffles, contests, and price promotions need approval from the relevant regulator before ASC will screen the ad. DTI for most consumer promos, FDA for pharmaceutical promos, NTC for telco, CAB for airlines, PAGCOR for gaming. The permit number belongs in the creative.

Fix: Lock the promo permit before the creative brief, not the day before launch.

Bonus: the silent failure modes

• Hashtags carrying must-screen claims (#1, #1Choice, #BestInClass) embedded in social posts that themselves carry brand assets — these get screened.
• DR-registered vitamins missing the "with proper diet and exercise" qualifier on benefit claims.
• Real estate ads without the License to Sell number, project completion date, and DHSUD Advertisement Approval Number.
• Bank and credit card ads missing "Regulated by the Bangko Sentral ng Pilipinas." E-wallets, pawnshops, and remittance firms missing "Supervised by the Bangko Sentral ng Pilipinas."
• Alcohol ads missing the "DRINK RESPONSIBLY" end-frame or depicting the act of drinking (liquid entering the mouth or being swallowed) — both are prohibited.

How to operationalise this list

Treat it as a pre-flight checklist that the creative team reads before the brief goes to production, the strategist reads before the substantiation pack is built, and the account director reads before the final cut goes to ASC submission. Most rejections come from one team assuming another team checked the list. Put a name next to each line.

AdScan automates this checklist on uploaded creative. Drop in your next ad and we'll flag which of the twelve patterns is most likely to come back from screening. Get started.