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December 1, 2021 By: Asa Waldstein

Step #1 in reducing risk is removing high-risk “buzzwords”

Takeaway -

High risk “buzzwords” attract FDA/FTC “keyword web crawlers”

Step #1 in reducing online marketing risk is removing high-risk “buzzwords”.

These include Alzheimer’s, cancer, diabetes, PTSD, opioid support, depression, and of course COVID. Other “buzzwords” include pain, anxiety, inflammation, and arthritis.

Today’s warning letter is a smorgasbord of “buzzwords”. Read it here.

Authorities look at the 10,000-foot view of a company’s online persona. One “buzzword” will likely not attract a warning letter, but claims on social media, videos, blogs, product reviews, hashtags, and ingredients descriptions elevate risk. The authorities piece them together for one big picture of noncompliance.

The more “buzzwords” the higher chance of scrutiny. I suggest removing or replacing them with truthful, accurate, and not misleading options.

Examples:
Pain <> Discomfort
Anxiety <> Mental resilience or balanced mood support
Flu <> Seasonal immune support

Disclaimer: The educational information provided here is for informational purposes only. Contact an attorney for specific legal advice. Rule #1 in compliance is to ensure marketing is truthful and not misleading.

Written by

Asa Waldstein
Asa Waldstein
Asa Waldstein is a 24-year veteran of the dietary supplement industry, with experience spanning manufacturing, marketing, and regulatory compliance. He is the principal of Apex Compliance, a software company dedicated to streamlining regulatory marketing compliance for the dietary supplement and natural products sectors. Asa also leads Supplement Advisory Group, a boutique consultancy focused on marketing risk analysis, labeling, and practical compliance strategies for websites and social media. Asa has helped oversee three FDA GMP inspections with no 483s and was honored with the 2023 AHPA Herbal Hero Award and the 2024 What's Up Supps Policy and Change Agent Award. He currently serves as Chair of the American Herbal Products Association’s (AHPA) Cannabis Committee, helping shape policy and industry best practices
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