3 Animal Product Companies Receive Warning Letters
Extra attention is paid to animal CBD products
FDA has a low tolerance for animal product disease claims, especially when they include CBD.
FDA recently issued three warning letters to companies marketing their CBD products as safe solutions for animal ailments such as anxiety and cancer. Many of these lessons also apply to human products as well. I will focus on one of the more egregious letters.
FDA is looking at blogs. This is nothing new, but a friendly reminder that blogs, including those old “forgotten” posts, are considered active marketing. For example, when I run Apex Compliance on a website and see a lot of blogs from 2020, there is almost a guarantee that they will be filled with disease words. When I bring these up to clients, most of them don’t even know they were on their site. The key takeaway here is to review old marketing and social posts for compliance issues.
From warning letter. “On your blog post titled “Benefits of Mushrooms for Cats. Medicinal mushrooms are used for many purposes, to name a few: Fight viruses and bacterial infections.”
FDA is looking at YouTube. In this example, the FDA cited disease claims made on the company’s About section. I ran Apex Compliance, my marketing compliance software, on their YouTube channel. It conducted a full audio scan of the entire channel in one minute and found many more compliance concerns. Let me know if you are interested in learning more.
From warning letter. “On your CBD Dog Health YouTube page within the “About” section: Did you know that animals can benefit from CBD oil even more than humans can? Whether your dog is suffering from: Seizures.”
FDA is looking at socials. Here FDA cites the company for posting a picture of their product with disease claims in the image.
From warning letter. “On your November 15, 2024, Instagram post with a photograph of your Heal (product): CBD Oil for Dogs, Remedy: Tumors, Cysts, and Infections for Dogs.”
Curated testimonials are claims. On the Success Stories page, several testimonials were cited. FDA often considers grouping testimonials on its own page the same thing as curating. Engaging with reviews or curating them turns them into marketing.
After a lull in CBD-related warning letters, these are the first three in a while. The FDA has only issued two other CBD letters in the past six months, and these were for potentially risky injectable and CBD-infused tampon products. I am still surprised at the limited number of CBD warning letters, and perhaps this will signal an enforcement ramp-up.
FDA does not like CBD in animal products. In addition to disease claims, one of FDA’s concerns is with the apparent lack of safety data about when humans consume food that has been fed CBD.
From warning letter. “CBD products for food-producing animals raise concerns regarding the safety of the human food (meat, milk, and eggs) derived from those animals. There is currently a lack of data about the formation of residues in edible products of food-producing animals in association with the consumption of CBD products by those animals and about safe levels of any potential residues for the human consumer.”
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