3. PRODUCT CLAIMS

PURPOSES:
To ensure the truthfulness and accuracy of product statements.
To ensure substantiation and traceability of product statements.
To promote thorough understanding and knowledge of products and product statements.
To promote equal evaluation and comparison of like products.
To preserve the integrity and meaning of legitimate statements such as: “organically grown & certified organic,” “cruelty free,” “recycled” and “historical formula.”

SECTION 3.A
Product Claims / Substantiation of Health Benefit or Nutrient Content Statements / Standards:

1. Exhibitors must provide substantiation of health benefit statements, whether express, implied or contained in product names. Adequate substantiation, including (but not limited to), copies of complete published scientific studies with journal name, date, volume and authors' names must be provided at the request of a designated New Hope Natural Media representative.
2. A bibliography of research will not generally be adequate, unless it is accompanied by the above documentation.
3. Exhibitors must provide substantiation of nutrient or ingredient content claims, which may consist of a certificate of analysis or analytical results from a qualified testing laboratory.
4. Testing must follow good laboratory practices including method validation, calibration and confirmation by an independent (FDA-registered if possible) laboratory.

Product Claims / Substantiation of Health Benefit Statements / Guidelines:

1. Exhibitors are encouraged to provide and have available substantiation of all health benefit statements or ingredient content statements to any EXPO attendee.
2. All testing to validate health benefit statements or ingredient content statements should be performed by an independent, certified laboratory with published Good Laboratory Practices.

SECTION 3.B
Product Claims / Superlative Statements / Guidelines:

1. Superlative statements should only be made if they are true, and the exhibitor has substantiation of such statements.
Examples: Superlative statements include (but not limited to): "best in the world," "best product in the U.S.," "only the finest herbs," "only the purest water," "the only," "the most potent" and "the most effective."
2. Superlative statements should not be misleading.

SECTION 3.C
Product Claims / Personnel or Process Statements / Standards:

1. Individuals presented as doctors must have a full and accurate title such as N.D., M.D., Ph.D., D.Ed., O.M.D. Such individuals must disclose details of their education and training at the request of a designated New Hope Natural Media representative.
2. Titles and initials must be stated clearly and, if not commonly known, must be spelled out or explained.
3. Statements about facilities, staff, quality control procedures, manufacturing processes or testing must not be overstated. Proof of such practices or test results must be supplied at the request of a designated New Hope Natural Media representative.
4. Statements about institutions of higher education must be truthful, not misleading and must disclose the following information:
   A. The accrediting agency/agencies of the institution program stated.
   B. Whether the accrediting agency/agencies are recognized by the U.S. Secretary of Education.
   C. If the degree or credentials offered are recognized by other institutions of higher education.
   D. Whether the degree or credential qualify the recipient to take state board exams in states where licensing is required.

SECTION 3.D
Product Claims / Disease or Health Benefit Statement / Standards:

In accordance with the Dietary Supplement Health and Education Act of 1994 (DSHEA), and the U.S. Food, Drug and Cosmetic Act, dietary supplement, food and cosmetic products and their labeling must not claim to treat, prevent, mitigate, cure or reduce the risk of diseases, unless the complete FDA-approved unqualified or qualified health claim is used on the labeling. The FDA considers that if a statement about a product or ingredient, claims to diagnose, mitigate, treat, cure, or prevent disease or if it has an effect on a specific disease, class of diseases or on the characteristic signs or symptoms of a disease, the product will be subject to regulation as a drug unless the claim is an authorized health claim for which the product qualifies.

1. Product labeling including sales and marketing material must not express or imply claims to diagnose, treat, cure, prevent or mitigate any diseases, including (but not limited to), cancer, heart disease, AIDS, diabetes, Alzheimer's disease, etc.
2. Substantial scientific data, to be determined at the discretion of a New Hope Natural Media representative, will be required to support benefit statements pertaining to such diseases. The data if published must include journal name, date, volume and authors' names.

SECTION 3.E
Product Claims / Organic Statements / Standards:

1. “Organic” must be used truthfully in all statements.
2. All organic ingredient, product and production statements must have current USDA-accredited, third-party certification for compliance with the USDA's National Organic Program or other internationally recognized organic certification program.
3. Exhibitors claiming "certified" organically grown or processed must have on file the appropriate certification documents, and such documentation must be available at the request of a New Hope Natural Media representative.

Product Claims / Organic Statements / Guidelines:

1. Exhibitors should provide substantiation of organic statements at the request of any EXPO attendee.
2. Organic certification documents should be freely available on request. Labels and literature should offer this documentation to consumers.

SECTION 3.F
Product Claims / Pesticide Free Statements / Standard:

1. Statements such as “pesticide free,” “unsprayed" and “herbacide free” must be documented. Information supporting such statements must be available at the request of a designated New Hope Natural Media representative.

SECTION 3.G
Product Claims / “No” and “Free” Statements / Standards:

1. “No,” “low,” “lite” and “free” statements must comply with all applicable FDA and FTC regulations.
2. Such statements must not be deceptive and must fully disclose relevant facts. Examples: A statement of “no salt added” is deceptive if the product contains a high amount of sodium from hydrolyzed vegetable protein. “No oil” is deceptive when the product is naturally high in fat such as peanuts.
3. Products stating to be free of ingredients with a particular activity must disclose the presence of ingredients with similar activity. Example: Products that contain no caffeine but do contain guarana.
4. Such statements must be substantiated with documentation available at the request of a designated New Hope Natural Media representative.

Product Claims / “No” and “Free” Statements / Guideline:

1. If a product is said to be free of a substance that actually remains in residual amounts, the residual amount should be disclosed.

SECTION 3.H
Product Claims / Cruelty-Free Statements / Guidelines:

1. Products promoted as “cruelty free” and “not tested on animals” should comply with criteria established by such animal protection organizations as PETA and NAVS.
2. Documentation of “cruelty free” and “not tested on animals” statements should be available at the request of a designated New Hope Natural Media representative.

SECTION 3.I
Product Claims / Recycled Statements / Standards:

1. “Recycled” statements must be truthful and comply with applicable parts of FTC and EPA regulations.
2. Recycled materials used in food packaging must meet FDA regulations for food contact materials.

Product Claims / Recycled Statements / Guideline:

1. "Recycled" statements should be accurate and supported by a network of recycling centers in the U.S.

SECTION 3.J
Product Claims / Charitable Contribution Statements / Standard:

1. Charitable contribution statements must be supported by documentation and made available at the request of a designated New Hope Natural Media representative.

SECTION 3.K
Product Claims / Statements Involving Testing / Standards:

1. Test results referred to in promotional literature must be made available at the request of a designated New Hope Natural Media representative.
2. Testing statements must be significant and relevant and not confusing or deceptive.
3. Statements and conclusions made about test results must be logically derived from and supported by test data.
4. Photos and data derived from tests including stylistic or artistic renditions must be accurately and objectively labeled and interpreted.
5. Promotional literature must state if the test was conducted by an FDA-registered or certified independent laboratory or by the promoter of the claim.

Product Claims / Statements Involving Testing / Guidelines:

1. Promotional literature should cite the test method and the laboratory conducting the test.
2. Exhibitors are encouraged to provide test results to any EXPO attendee on request.
3. Exhibitors should disclose the source of funding for any tests cited.

SECTION 3.L
Product Claims / Disallowed Statements / Standard:

1. The following products may not be exhibited at Expo:

• Alternatives to street drugs
• Recreational euphoriants/stimulants
• Sexual stimulants/enhancers (reviewed on a case-by-case basis)
• Remedies for nuclear, biological, or chemical contaminants.

2. Natural Products Expo evaluates all promotional literature and/or labeling as a whole, including text, product names and images used. Natural Products Expo allows products that support natural sexual function, but not those that seek to enhance sexual pleasure, endurance or those marketed as aphrodisiacs.

3. New Hope Natural Media strictly prohibits the exhibit, advertising and promotion of products that claim to protect against, detect, prevent or treat nuclear, biological or chemical contaminants.

4. PRODUCT LABEL REGULATORY COMPLIANCE

All labels and labeling must be truthful and not misleading and must comply with current FDA regulations.

5. LABELS, LABELING AND LITERATURE

PURPOSES:
To ensure understanability and traceability of product literature.
To promote equal evaluation and comparison of like products.
To ensure guarantees are fair and honored.

SECTION 5.A
Labels, Labeling and Literature / Names and Addresses / Standards:

1. Product labels and promotional literature must include the full name of the manufacturer or distributor and mailing address.
2. Literature that does not list a trade name must have the exhibitor’s name, city, state and zip code and/or the phone number; or it must have the name and address or phone number of the party responsible for compilation and dissemination of the information. Published “third-party literature” must bear a full citation.

Labels, Labeling and Literature / Phone Numbers / Guideline:

1. Product labels and promotional literature should include a phone number for the manufacturer or distributor.

SECTION 5.B
Labels, Labeling and Literature / Surveys / Standards:

1. Survey statistics and conclusions must have a reference that includes the following information:

• Methodology of survey
• Who conducted the survey
• The date the survey was conducted
• A written offer explaining how to obtain a copy of the survey.

2. Survey results must not be misrepresented.

Labels, Labeling and Literature / Surveys / Guideline:

1. Surveys should contain the following information:

• Selection criteria for survey population
• Number of people surveyed
• Margin of error of the survey
• Source of funding for the survey.

SECTION 5.C
Labels, Labeling and Literature / Quotes / Standards:

1. Quotes must not be misrepresented by being taken out of context.
2. Endorsements by consumers must represent what the typical experience of customers would be, not the experience of just a few customers. Simply stating that “Not all consumers will get these results” or “your results may vary” is not enough.
3. Endorsement quotes must cite the speaker, date and source of the quote.

SECTION 5.D
Labels, Labeling and Literature / Photos and Illustrations / Standards:

1. Photos and illustrations may not be deceptive or misleading.
2. Photos used in labeling and literature that depict any aspect of a product’s processing, manufacture or test must be of the manufacturer’s facility or accurately labeled with the name of the Photos and Illustrations/Standards facility pictured and its relationship to the exhibitor’s product.
3. Before/after and comparison photos must be used in the following manner:

• Include a caption stating the time of the first photo and the time of the second photo.
• Exposure and print techniques must be identical for each photo.

4. Photos and illustrations should not contain additional misleading features or characteristics.

SECTION 5.E
Labels, Labeling and Literature / Art and Technical Terms / Standards:

1. Artistic or contrived terms used in labeling and literature must be understandable.
2. The use of a term must not differ from its commonly accepted meaning.

Art and Technical Terms / Guideline:

1. A coined term or descriptive phrase should not be used to imply one product’s superiority over another solely by virtue of the use of that coined term or phrase.

Section 5.F
Labels, Labeling and Literature / Comparison and Negative Advertising / Standard:

1. All comparison and negative advertising must comply with FTC regulations. FTC defines comparison advertising as that which “compares alternative brands on objectively measurable attributes or price and identifies the alternative brand by name, illustration or other distinctive information.”

Labels, Labeling and Literature / Comparison and Negative Advertising / Guidelines:

1. Data cited should be made available on request to any EXPO attendee.
2. Negative statements about companies or products should be thoroughly documented and such documentation made available at the request of a designated New Hope Natural Media representative.

Section 5.G
Labels, Labeling and Literature / Guarantees / Standards:

1. Guarantees must be easily understandable and must not be misleading and must include relevant terms and conditions.
2. Companies offering guarantees must honor the guarantee.

Section 5.H
Labels, Labeling and Literature / Use of Information / Standard:

1. The exhibitor is responsible for the accuracy of all information present in the booth that pertains to products or services offered.

Labels, Labeling and Literature / Use of Information / Guidelines:

1. Information that is primarily educational and helps to better understand the product is encouraged.
2. Information should state product limitations and encourage an integrated approach to wellness using a variety of techniques.
3. Information from an impartial third party is encouraged.
4. Information about the cultural context of use or philosophical basis of formulation is encouraged.
5. Information which addresses cultivation techniques and ingredient and product processing methods is encouraged.
6. Information should explain technical terms and cite references for any statements made.

6. TRADE SHOW ACTIVITIES

PURPOSES:
To ensure EXPO attendees are not placed at risk by unsafe practices by exhibitors and are properly informed.
To ensure compliance with exhibit hall rules and local ordinances.
To encourage ethical behavior.

SECTION 6.A
Trade Show Activities / Medical Testing and Treatment / Standards:

1. All medical testing, diagnosis and treatment conducted within exhibits must be done by a qualified medical practitioner.
2. The medical practitioner’s title and qualifications must be prominently displayed.
3. Testing must be conducted in a safe manner.
4. Test or treatments resulting in medical waste or which may contaminate attendees are strictly prohibited. Example: Drawing blood or other bodily fluids; the use of needles.
5. A written report stating the test’s validity and usefulness must be available to attendees.

SECTION 6.B
Trade Show Activities / Product Manufacture and Preparation / Standards:

1. Products or samples manufactured or prepared at EXPO must comply with federal, state and local regulations pertaining to food preparation.
2. Products or samples that cannot comply with these regulations must not be offered for consumption and may only be used for demonstration purposes.

SECTION 6.C
Trade Show Activities / Sale of Products / Standard:

1. Food, beverages and other products intended for immediate consumption must be offered free of charge.

SECTION 6.D
Trade Show Activities / Ethical Considerations / Guideline:

1. Exhibitors are requested to adhere to ethical considerations in areas including but not limited to the following:

• Racism
• Sexism
• Sexually explicit materials
• Animal Cruelty
• Decorum
• Environmental concerns.

SECTION 6.E
Trade Show Activities / Seminars / Standards:

1. Seminar speakers, including exhibitors and representatives from companies who pay to give an Exhibitor Presented Seminar at Natural Products Expo, must not make defamatory, libelous or slanderous statements about an exhibitor, company or person during a seminar.
2. Information given at seminars must be truthful and non-misleading.
3 . Substantiation for claims and statements made during seminars must be provided to a designated New Hope Natural Media representative on request.

APPENDIX

GUIDELINE: Not mandatory at this time but represent long-term goals to raise the industry’s integrity.

HEALTH BENEFIT STATEMENT: A statement which identifies a potential benefit to health from a product. This is not to be construed to mean a drug claim, a NLEA health claim, or a DSHEA statement of nutritional support.

LABELS: Include all packaging and any written materials attached to or accompanying the product.

LABELING: Includes all packaging, promotional materials, brochures, and any other written materials attached to or accompanying the product; verbal or visual representations including video, audio- tapes and signage.

LITERATURE: Includes promotional materials, advertisements, brochures, magazine articles, books and other printed matter that may or may not be about the product but is not physically attached to the product.

ON FILE: The company has substantiating information in its records at its head- quarters and the information is easily accessible upon request.

QUALIFIED MEDICAL PRACTITIONER: A graduate of an accredited institution of higher learning.

STANDARD: A minimum requirement exhibitors must meet to participate in a NATURAL PRODUCTS EXPO.

GLOSSARY OF ACRONYMS

EPA Environmental Protection Agency www.epa.gov

FTC Fedral Trade Commission www.ftc.gov

FDA Food and Drug Administration www.fda.gov

HPUS Homeopathic Pharmacopoeia of the United States www.hpus.com

NAVS National Anti-vivisection Society www.navs.org

PETA People for the Ethical Treatment of Animals www.peta-online.com