Skip to content
Stetwright

Can I say it?

Can I say “doctor formulated” in a skincare ad?

It depends. 2 rules fired across 3 sample sentences, and the checker's own text explains why.

The short answer

It depends. The checker warns on this wording but does not block it. The first rule it hits is CG-TES-009. Its reason: Saying doctors or other experts recommend, approve or formulated a product is an expert endorsement claim. It must be true, current and typical of the experts who actually reviewed it, and any payment must be disclosed.

Source the rule cites: 16 CFR 255.3 - expert endorsements; 16 CFR 255.5 - disclosure of material connections; FTC Act section 5

Checked as an ad promoting a supplement or wellness product.

A clear result is not an all-clear. The checker flags wording for review and does not know your evidence, your state or your platform's review. Read the limitations.

Sample wording, run through the checker

These are sentences written to contain the phrase, not real claims. Each ran through the real engine and the shipped rule-set when this site was built.

Sample 1 · actual checker output2 rules fired

Doctor formulated and tested.

  • WarningCG-TES-009Patient quotes and reviews. Matched: “Doctor formulated”
  • WarningCG-EFF-005Efficacy and proof. Matched: “Doctor formulated”
Sample 2 · actual checker output2 rules fired

Our doctor formulated serum is lab tested.

  • WarningCG-TES-009Patient quotes and reviews. Matched: “doctor formulated”
  • WarningCG-EFF-005Efficacy and proof. Matched: “doctor formulated”
Sample 3 · actual checker output2 rules fired

Doctor formulated to fix sun damage.

  • WarningCG-TES-009Patient quotes and reviews. Matched: “Doctor formulated”
  • WarningCG-EFF-005Efficacy and proof. Matched: “Doctor formulated”

What to say instead

This version came back with no rule fired:

Our serum was developed with input from our medical director. Read the full ingredient list before you buy.

Actual checker output: no rule fired. It still has to be true for your business.

What the rules themselves suggest:

  • CG-TES-009 Name the expert and credential, say what they examined and disclose any connection, or remove the claim.
  • CG-EFF-005 Say who formulated it by name and credential, or drop the phrase.

The rules behind this answer

Reason, source and citation for each rule that fired, in the checker's own words. Blocking rules come first.

  1. CG-TES-009 · Warns · Citation checked against stored text

    Saying doctors or other experts recommend, approve or formulated a product is an expert endorsement claim. It must be true, current and typical of the experts who actually reviewed it, and any payment must be disclosed.

    Source: 16 CFR 255.3 - expert endorsements; 16 CFR 255.5 - disclosure of material connections; FTC Act section 5

    Safer wording: Name the expert and credential, say what they examined and disclose any connection, or remove the claim.

    16 CFR 255.3, 16 CFR 255.5 · Needs counsel review

  2. CG-EFF-005 · Warns

    Clinical or doctor-formulated language implies testing or endorsement that you must be able to show.

    Source: FTC Health Products Compliance Guidance; FTC Act section 5

    Safer wording: Say who formulated it by name and credential, or drop the phrase.

    See source text · Needs counsel review

Background: Substantiation in the glossary.

Questions

Which rule covers formulation claims?

Rule CG-TES-009. It cites 16 CFR 255.3, 16 CFR 255.5. The rule's reason: Saying doctors or other experts recommend, approve or formulated a product is an expert endorsement claim. It must be true, current and typical of the experts who actually reviewed it, and any payment must be disclosed.

What should I write instead?

The rule's own suggestion for rule CG-TES-009: Name the expert and credential, say what they examined and disclose any connection, or remove the claim.

If the checker shows nothing, can I publish?

No. A clean result means none of the checker's rules matched. It does not weigh your evidence, your state or your platform's review, and it is not legal advice. Read the limitations page for what it misses.

Next step

Check your own wording

Paste your copy into the free checker. Every flag names its rule and its source.