FACEGYMPRO.COM
Why this site · and why it is lawful

Two different devices now share one name. This page explains why we compare them — and why doing so is legal.

Since April 2026 there are two physically different products sold as the FaceGym Pro: the device made in Japan and sold from 2019 to 2025, and a different device, rebuilt in 2026, that carries the same name and a similar price. They are not the same machine. This page explains, plainly, why an independent comparison that names both brands is permitted under UK law, and the standards we hold ourselves to so the comparison stays fair.

The short version. UK law does not stop you from naming another company's trade mark. It lets you name it in genuine, factual comparison — and it specifically requires that such comparison must not create confusion between products. Where two products are sold under the same name, an honest comparison is one of the few things that actually reduces the confusion the law is concerned with.

The problem we exist to fix

A consumer searching for "FaceGym Pro" today can land on listings, reviews and editorials describing two materially different devices without realising it. Major retailers still describe the original — "patented triple-wave technology," "completely randomised," "diamond-faceted probes," made in Japan — while FaceGym's own current page describes a device "rebuilt entirely from the ground up," brought "in-house," running a fixed frequency "up to 1.5 kHz" across "10 power levels." Buyers have publicly reported receiving a different unit from the one they thought they were ordering.

That gap — same name, different machine — is the exact kind of marketplace confusion consumer-protection law is designed to prevent. This site sets the two side by side, with sources you can open and check, so a buyer about to spend roughly £500 knows which device is in the box.

Why naming both brands is lawful

Comparing named products, and referring to a competitor's registered trade mark in order to do so, is expressly permitted under UK law when the comparison is honest and meets defined conditions. The relevant authorities:

1. The Trade Marks Act 1994 — honest use

A registered trade mark may be used by another party to identify the proprietor's own goods, and to compare against them, provided the use is in accordance with honest practices in industrial and commercial matters. UK courts have consistently read this purpose as being to permit comparative advertising rather than restrict it.

Trade Marks Act 1994, s.10(6) and the honest-practices limitation in s.11(2). See legislation.gov.uk. legislation.gov.uk.

2. The Business Protection from Misleading Marketing Regulations 2008 — the test for comparison

Regulation 4 sets out when comparative material is permitted. We treat its conditions as the rulebook for this site. Comparison is allowed where it compares products meeting the same need, is not misleading, objectively compares verifiable features, does not create confusion between the brands, does not denigrate the competitor, and does not take unfair advantage of its reputation.

Business Protection from Misleading Marketing Regulations 2008, reg. 4. Full text at legislation.gov.uk. legislation.gov.uk.

3. CJEU case law — confirmed for trade marks specifically

In O2 Holdings v Hutchison 3G (C-533/06, 2008) the Court held that a trade-mark owner cannot use its rights to stop a competitor naming its mark in a comparison, provided the comparison is not misleading and creates no confusion as to origin. In Gillette v LA-Laboratories (C-228/03, 2005) the Court confirmed a third party may use another's mark where it is necessary to indicate what a product is or what it relates to — again, subject to honest use.

CJEU C-533/06 O2 v Hutchison 3G; CJEU C-228/03 Gillette v LA-Laboratories. (Retained as persuasive authority in the UK.) O2 v Hutchison 3G; Gillette v LA-Laboratories.

The five conditions we hold ourselves to

Because the legality of a comparison depends on how it is done, we apply Regulation 4 to every claim on this site:

  1. Like-for-like: Like-for-like. We compare two products that meet the same need — at-home EMS facial devices sold under the same name.
  2. Objective & verifiable: Objective and verifiable. Every factual claim links to a primary source: the manufacturers' own pages, major retailers, the printed packaging, or peer-reviewed journals.
  3. No confusion: No confusion. We make unmistakably clear which device is which, and that this site is independent of FaceGym Ltd.
  4. No denigration: No denigration. We state where the newer device is genuinely good. We describe the difference; we do not insult the product or the company.
  5. No reputation riding: No riding on reputation, no "imitation" claims. We use the names only to identify the products being compared, not to imply endorsement or to present either device as a copy of the other.

On the FDA and CE/UKCA marks — stated neutrally

The original device additionally held FDA 510(k) Class II clearance for the United States market. The 2026 device carries CE / UKCA marking. Both are legitimate regulatory routes: CE/UKCA marking is the standard, valid conformity route for an over-the-counter cosmetic EMS device sold in the UK and EU. The difference is which markets each device was cleared for and under which framework — not that one is "approved" and the other is not. Neither device is a medical treatment; both are over-the-counter cosmetic tools.

Who runs this site

This comparison is produced and operated by LARA Media Group (United Kingdom), an independent publisher of direct product comparisons. It is not affiliated with, authorised by, or endorsed by FaceGym Ltd. "FaceGym" and "FaceGym Pro" are trade marks of FaceGym Ltd; "PureLift" is a trade mark of its respective owner. All marks are used only to identify the products being compared. Statements about the relationship between the two devices reflect the manufacturers' and major retailers' own published descriptions, each linked from the comparison.

Specifications and prices are current as of June 2026 and may change; verify on each brand's own site before purchase. Results vary by individual. This page explains the operator's basis for publishing a lawful comparison and is not legal advice.

Sources

  • Trade Marks Act 1994, s.10 — legislation.gov.uklegislation.gov.uk ↗
  • Business Protection from Misleading Marketing Regulations 2008, reg. 4 — legislation.gov.uklegislation.gov.uk ↗
  • CJEU C-533/06 O2 v Hutchison 3G — curia.europa.eucuria.europa.eu ↗
  • CJEU C-228/03 Gillette v LA-Laboratories — eur-lex.europa.eueur-lex.europa.eu ↗
  • CMA guidance for digital comparison tools (CARE principles) — Competition and Markets Authority