Do refer to aroma and atmosphere (“has an uplifting aroma,” “creates a relaxing atmosphere”).
Do use cosmetic claims (“cleanses,” “improves appearance”).
Do use structure-function claims only with products labeled for internal use.
Use words such as “health,” “wellness,” “supports,” “maintains,” etc.
Refer to general body parts and systems (“for heart health,” “supports the respiratory system”).
Refer to normal conditions associated with a natural state or process (“morning sickness during pregnancy,” “hot flashes during menopause”).
Use qualifiers such as “mild,” “typical,” “normal,” “occasional,” or other words to distinguish a temporary or minor condition from a symptom of disease (“occasional stomach upset,” “muscle soreness following exercise”).
Do use the FDA disclaimer only with structure-function claims.
Don’t use disease claims.
Don’t use words such as “disease,” “illness,” “cure,” “treat,” “repair,” “chronic,” etc.
Don’t refer to any disease or illness, such as cancer, diabetes, autism, cold, flu, etc.
Don’t refer to symptoms of disease such as coughing, sneezing, fever, etc.
Don’t recommend a product as a substitute for a drug.
Don’t recommend a product to augment a therapy or drug.
Don’t imply a disease claim through pictures or symbols.
Cosmetic claims: Claims that a product cleanses, beautifies, promotes attractiveness, or alters appearance.
Structure-function claims: Claims that a product helps the body stay healthy and function normally or contributes to general wellbeing, e.g., “supports the immune system.”
Disease/drug/medical claims: Claims that a product diagnoses, prevents, treats, or cures disease.
Disease: Damage to an organ, part, structure, or system of the body such that it does not function properly.
FDA disclaimer: “These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent disease.”
Prevents, treats, cures any kind of sickness, illness, infection, disease, chronic condition, etc.
Supports, or maintains health, wellness, or structures and functions of the body like the brain, the heart, the liver, muscles and joints, the respiratory system, cognitive function, etc.
Fights colds and flu
Supports the immune system
Relieves occasional sleeplessness
Relieves head and neck tension
Soothes arthritis pain
Supports cartilage and joint function
Reduces depression and anxiety
Reduces anxious feelings, helps you relax and soothe away tension, relieves restlessness, eliminates irritability
Maintains healthy cholesterol levels that are already within the normal range
For ear infections
For occasional ear discomfort
Helps fight obesity
Helps with weight loss plan
For dementia and Alzheimer’s
For mild memory problems associated with aging
For edema associated with pregnancy
For hyperemesis gravidarum
For ordinary morning sickness
Supports bone health
Treats cystic acne
Treats mild acne
Relieves heartburn or acid indigestion (without further qualification)
Relieves occasional or mild heartburn or acid indigestion; also, for occasional upset stomach, aids digestion, and alleviates gas or bloating
For nausea (without further qualification)
For occasional nausea or motion sickness
Relieves constipation (without further qualification)
Relieves occasional constipation
Relieves pain (without further qualification)
Relieves minor discomfort or discomfort associated with non-disease states such as minor muscle aches following exercise
For chronic fatigue or daytime drowsiness
Helps restore mental alertness or wakefulness when experiencing fatigue or drowsines
Fights germs, viruses, bacteria, or allergens
For seasonal threats
Use as part of your diet to help maintain an already healthy blood sugar level
Along with better dietary and exercise patterns, can prevent conditions like heart disease, stroke, diabetes, and cancer
Along with better dietary and exercise patterns, can contribute to better health.
*These are based on examples from the FDA and are not intended to simply be substitutes for disease claims. Structure-function claims should only be used when substantiated for the product being discussed.