Most common supplement health claims to avoid and what to say instead
![Most common supplement health claims to avoid and what to say instead Most common supplement health claims to avoid and what to say instead](https://eu-images.contentstack.com/v3/assets/blt09e5e63517a16184/blt550e946e24bf2495/64f1e2ab2a91e05b4e26e2d6/Other_20immunity_20claims.jpeg?width=700&auto=webp&quality=80&disable=upscale)
These types of claims can be acceptable for homeopathic products, but generally not for vitamins/herbal products. Don't say: Cures the common cold, fights influenza and viruses, relieves colds and flu. Do say: Supports immune system, boosts immune function, helps immune system natural defenses. "Helps lessen cold duration" or "can ease cold symptoms" is reserved for homeopathic products.
(Blackcurrant, zeaxanthin, astraxanthin and other carotenoid/flavenoid ingredients). This is more of a supplier issue since several do release high quality, credible studies on these types of ingredients. However, that science, until it is reviewed by the FDA, provides the substantiation for structure function claims only. Don’t: Refer to macular degeneration, cataracts, glaucoma, vision loss even if in a statistical, true statement or it becomes an implied disease claim about the product; reduces risk of any of the previously mentioned conditions; improves eyesight. Do say: Promotes/supports/maintains normal vision, vision health and/or function, good for retinal function.
These are drug claims and not allowed for dietary supplements/ingredients. Claims are very rampant about cosmetics/topical products, which is also non-compliant; though, these types of claims are allowed for homeopathic products. (See Is it a Cosmetic, a Drug, or Both? (Or is it Soap?) for more information.) Don’t say: Relieves/clears/prevents/treats eczema, psoriasis, dermatitis; for eczema and psoriasis; for serious or chronic skin irritations; removes/kills bacteria that cause… Do say: Soothes irritated skin; hydrates, moisturizes, softens, smoothes, soothes rough, red, dry, flaky, itchy skin; for minor skin irritations; keeps skin radiant, smooth, soft, silky, healthy.
Anything referring to diabetes, blood sugar mitigation, insulin function, could all fall under the FDA radar. The FDA has been watching diabetes claims very closely for the last several years. Don’t say: Regulates, controls, stabilizes blood sugar; affects insulin regulation/sensitivity in any way; increases insulin/receptor activity; reduces/eliminates/lowers blood sugar spikes; reduces/lowers glycated or glycosylated hemoglobin (HbA1c); glucose management/support for diabetics and pre-diabetics. Do say: Healthy blood sugar management, promotes/supports healthy and normal blood sugar; balances blood glucose; helps with/promotes/supports normal insulin function; lowers glycemic index; helps to balance postprandial response; nutritional/supplement support for diabetics.
This is an area where the FDA and FTC have made the biggest impact upon claims being made about dietary supplements. Despite the rampant spiking and adulteration problem and the few products with questionable claims, most of what New Hope's Standards Department sees now about weight loss is acceptable, so long as specific disclaimers are also present. Some of these various disclaimers include: results may vary, these are not typical results, a program that includes “x” product with a balanced diet and exercise…. Claims in which the mechanisms are described, such as lower glycemic index, jump starts the metabolism, and some fat-metabolism claims may also be acceptable. Within the literature and advertisements submitted, Zerbib and team don’t see too many "lose weight overnight while you sleep," "lose 10 lbs in a week," "permanent loss for everyone," "eat whatever you want" types of statements and would automatically question and suspect that the products promoted with these types of claims are adulterated or spiked with prescription or illegal drugs. Don’t say: FTC's Red Flag Bogus Claims say it all. Do: Have substantiation first and always include disclaimers when referencing the findings from your studies (see above); some mechanism statements (also mentioned above) may be acceptable
If not for cold and flu, other immunity claims are often inferring some type of cancer. There are many statements describing the biological/biochemical mechanism of what the product/ingredient does in the body, and some of these claims may be acceptable, however, the overall message must remain in structure function format. Don’t say: Reducing/inhibiting tumor growth, increases killer-T cell activity, activates NK cells, prevents/reduces DNA damage. Do say: Promotes/maintains/supports/strengthens immunity. Enhances and balances immune response are also acceptable.
These may be acceptable for homeopathic products, but are generally not accepted for vitamin or herbal supplements. Seasonal claims may be acceptable. Don’t say: Relief of allergy symptoms, watery eyes, runny nose, sneezing, etc.; for hay fever, reactions to animal dander and pollen, etc.; natural anti-histamine, inhibits histamine. Do say: For seasonal upper respiratory challenges, promotes upper respiratory health, soothes, cleanses the nasal passages (for sprays).
Like inflammation, pain relief claims are everywhere for a very wide range of products and will depend upon other text and/or images present. Under the DSHEA, supplements and dietary ingredients may not claim to relieve pain—this is a drug claim. This is also true for topicals and cosmetics, and there are lots of those as well. For topical products, it will come down to the ingredients as to whether a pain relief claim is acceptable. Do say: Pain due to exercise or over-exertion may be allowed. “Temporary relief of pain due to…” claims are allowed for homeopathic products.
Lots of natural toothpastes and chewing gums do not contain the “right” ingredients to make this cavity claim. Xylitol products may NOT make this claim. Toothpaste is regulated as an OTC drug, which requires a Drugs Facts panel and FDA inspection of the manufacturing facility. All-natural toothpastes that do not contain any of the FDA-monograph ingredients for anticaries/anti-plaque may only use structure function claims (See Do say below). The FDA allows the following health claim related to Xylitol: “The claim shall state that the noncariogenic carbohydrate sweetener (e.g. Xylitol) present in the food "does not promote," "may reduce the risk of," "useful [or is useful] in not promoting," or "expressly [or is expressly] for not promoting" dental caries.” (See Code of Federal Regulations Title 21 101.80 ) Don’t say: Fights/prevents cavities, tooth decay; reduces risk of periodontal or gum disease; plaque/cavity-fighting; fights/removes/reduces plaque/bacteria that causes… Do say: Supports/promotes/maintains oral health; maintains healthy teeth and gums; promotes oral hygiene; freshens breath; cleans teeth.
Surprisingly, “lowers cholesterol” is an acceptable claim for a small handful of supplements and/or ingredients. Some fiber (e.g. psyllium husk, oat/barley bran) and plant sterol (e.g. soy) products are allowed to make these claims. However, the full language of the FDA approved health claim must be present with this type of claim. For any product that meets the criteria to use an FDA-approved health claim, the claim shall not attribute any degree of the reduction in risk of “x.” (See FDA’s Food Labeling Guide: Appendices B, C, and D for more health claims information). Lowers cholesterol all by itself—it is a drug claim. For all other products targeting cholesterol mitigation for heart health: Don’t say: Reduces/lowers/manages cholesterol or triglycerides. Do say: Supports/maintains/promotes healthy/normal cholesterol levels.
Similar to pain relief claims (see next category), anti-inflammatory claim acceptance will depend upon whether other text and/or images imply the type of inflammation, say, due to arthritis, heart disease, infection or associated with an image of joints, x-rays, none of which would be compliant. Anti-inflammation claims on their own, left completely vague, or accompanied with an antioxidant claim or due to exercise or over-exertion we may allow. Don’t say: Reduces/prevents inflammation, inflammation due to arthritis, inflammation associated with heart disease, natural COX-2 inhibitor. Do say: Balances/promotes/supports a healthy inflammation response, helps with inflammation due to exercise or over-exertion.
Similar to pain relief claims (see next category), anti-inflammatory claim acceptance will depend upon whether other text and/or images imply the type of inflammation, say, due to arthritis, heart disease, infection or associated with an image of joints, x-rays, none of which would be compliant. Anti-inflammation claims on their own, left completely vague, or accompanied with an antioxidant claim or due to exercise or over-exertion we may allow. Don’t say: Reduces/prevents inflammation, inflammation due to arthritis, inflammation associated with heart disease, natural COX-2 inhibitor. Do say: Balances/promotes/supports a healthy inflammation response, helps with inflammation due to exercise or over-exertion.
Avoid FDA altercations and do right by consumers with this guide to the most common disease claims that are used and abused on supplements—as decoded and diffused by Michelle Zerbib, New Hope Natural Media's standards manager.
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