Pursuant to the Food, Drug & Cosmetic Act, the FDA and FTC require that we follow a specific and detailed protocol about what we can say about our products online, over the phone, and in person. 

Anyone working for/with Adapt Naturals, including our affiliates, must adhere to this protocol to ensure our company maintains good standing with the FDA and other regulatory agencies. 

As an affiliate, you are responsible for what you say about our products to others. What you say could affect our standing with the FDA, so if you’re unsure if you can say something, please ask, and we can help clarify.

The FDA will litigate against any company that makes health claims for its products. This includes claims made by any team member or affiliate on our website and social media properties, your website and social media properties, via email, over the phone, or in person. 

Despite FDA and FTC regulations, many companies continue marketing their supplements by making illegal claims. This is a lawsuit waiting to happen—and it’s a completely unnecessary risk. At Adapt Naturals, we believe we can successfully grow our company and create mutually beneficial partnerships without violating FDA and FTC regulations. 

How to stay in compliance with the FDA

Overview

Stick to structure-function claims and avoid health claims

• See the “Structure-Function claims criteria” section below for specific examples

Do not mention the name of any disease (e.g., Hashimoto’s, diabetes, etc.) or syndrome (e.g., PMS, IBS, constipation, etc.) in your copy

Use “positive” language rather than “negative” language

Examples of positive: Helps, supports, promotes, contributes to, regulates, improves, etc.

Examples of negative: Stops, fights, reduces, prevents, etc.

• Avoid the term “anti-,” i.e., anti-inflammatory, antioxidant, anti-aging, etc.
• Avoid the term “inflammation” in any form  

The swipe copy we’ve provided you adheres to these guidelines. If you make significant changes to that copy, we suggest you share it with us before publishing so we can review it for compliance.

Structure/function claims criteria:

#1: A claim may not suggest that the product has an effect on a specific disease or class of disease.

Not permitted:

• Reduces the pain and stiffness associated with arthritis.
• Helps alleviate the pain associated with migraine headaches.
• Helps alleviate the blues associated with emotional despair (i.e., despair = depression).

Permitted:

• Helps alleviate the occasional blue feeling everyone experiences from time to time.
• Helps maintain joint health and flexibility.
• Helps maintain a healthy heart.

#2: A claim may not refer to a characteristic sign or symptom of a disease or class of diseases.

Not permitted:

• Lowers serum cholesterol levels.
• Relieves painful joints. 
• Lowers blood sugar levels.

Permitted:

• Helps maintain cholesterol levels already within the normal range.
• Helps maintain proper joint function.
• Helps maintain healthy blood sugar levels.

#3: References to signs and/or symptoms of natural states are permissible as long they are not uncommon and would not cause significant harm if left untreated.

Not permitted:

• Helps alleviate BPH.
• Relieves chronic constipation.
• Helps alleviate male potency problems (implied impotency claim).

Permitted:

• Alleviates mood swings and hot flashes associated with menopause.
• Alleviates occasional constipation.
• Promotes sexual arousal and performance.

#4: The use of the terms disease, diseases, antiviral, antibacterial, antiseptic, antibiotic, analgesic, diuretic, antidepressant, vaccine, analgesic, or any other word suggesting that the product belonged to a class of products intended to cure, treat, or prevent disease, is not permitted.

Not permitted:

• Stimulates the body's antiviral capacity.
• Helps individuals using antibiotics maintain normal intestinal flora.
• Helps alleviate depression.

Permitted:

• Helps maintain proper immune function.
• Helps reduce stress and tension.
• Restores intestinal flora.

#5: A claim may not suggest that the supplement or its ingredients belong to a particular class of drugs or is a substitute for a particular therapy.

Not permitted: 

• Herbal antidepressant
• Helps maintain joint health without the use of NSAIDs.

#6: A claim may not suggest that a product is useful as a companion to regular drug therapy or that it prevents or treats adverse events associated with a disease if the adverse events are also disease conditions.

Not permitted:

• Helps maintain blood sugar levels in insulin-dependent people.
• Helps stimulate the immune system when undergoing chemotherapy.

Permitted: 

• Helps maintain intestinal flora.
• Use as part of a healthy diet to help maintain healthy blood sugar levels.