Product Tags & Metatags Attract FDA Attention
Everything used to market products must be compliant
Website product tags and metatags continue to attract FDA attention in warning letters.
This year three warning letters mention product tags or “category” tags. These tags help people find products when they search for things on Google or a website, and they are considered marketing in the eyes of the FDA and FTC.
Although these tags are an “extension of the label,” they are not likely to attract a warning letter on their own. However, they signal intended use, which can lead authorities to a commercial website to keep digging for claims once there.
Here are some examples involving product tags and metatags with disease claims. It’s worth noting that additional high-risk website and social media claims are also present in each warning letter. This is an important reminder that compliance is not done in a vacuum, and all online content must be free of high-risk claims to avoid warning letters.
From Warning Letter: “From the product webpage at …. Tags: anxiety, . . . memory, mental performance, natural depression remedy”
Read this warning letter here.
From Warning Letter: “Tags: anti-viral, COVID, COVID-19, Cure”
Read this warning letter here.
From Warning Letter: “The above noted website claims are supplemented by metatags used to bring consumers to your website ….. through Internet searches. The metatags are: • “Take Altitude RX for altitude sickness prevention…”
Read this warning letter here.
Here is my “All Marketing is Labeling” video.
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