December 8, 2021
By:
Asa Waldstein
Using words such as “inflammation” increase warning letter chances
Takeaway -
Replace “high risk” words with lower risk alternatives
High risk words should be avoided in all forms of marketing. The words “inflammation” or “anti-inflammatory” is being referenced in many warning letters.
Read the full warning letter here.
If truthful and not misleading replacing “inflammation” with words such as discomfort, soothe, support-comfort, body-resilience can help convey a marketing message in a lower risk manner.
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 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