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Can I say it?

Can I say “fights COVID” in a supplement ad?

Usually no. 4 rules fired across 3 sample sentences, and the checker's own text explains why.

The short answer

Usually no. The checker blocks the bare phrase in this setting. The first rule it hits is CG-DIS-012. Its reason: Claims that a product prevents, treats or fights a virus or infection, including COVID-19, are disease claims. FDA and FTC have sent many warning letters on them.

Source the rule cites: FDCA 201(g)(1); 21 CFR 101.93(g); FTC Act section 5; FDA and FTC warning letters on unapproved COVID-19 products

Checked as an ad promoting a supplement or wellness product. Context changes the result. The same samples hit these blocking rules: 2 in a drug or device ad, 4 in a supplement ad, 2 in a clinical service ad.

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 output4 rules fired

Immunity booster that fights COVID.

  • BlockingCG-DIS-012Disease claims. Matched: “fights COVID”
  • BlockingCG-DIS-016Disease claims. Matched: “Immunity booster that fights COVID.”
  • BlockingCG-RFA-001Disease claims. Matched: “fights COVID”
  • BlockingCG-RFA-004Disease claims. Matched: “Immunity booster that fights COVID”
Sample 2 · actual checker output4 rules fired

Our zinc lozenge fights COVID and the flu.

  • BlockingCG-DIS-012Disease claims. Matched: “fights COVID”
  • BlockingCG-DIS-016Disease claims. Matched: “Our zinc lozenge fights COVID and the flu.”
  • BlockingCG-RFA-001Disease claims. Matched: “fights COVID and the flu”
  • BlockingCG-RFA-004Disease claims. Matched: “fights COVID ”
Sample 3 · actual checker output4 rules fired

Fights COVID before you get sick.

  • BlockingCG-DIS-012Disease claims. Matched: “Fights COVID”
  • BlockingCG-DIS-016Disease claims. Matched: “Fights COVID before you get sick.”
  • BlockingCG-RFA-001Disease claims. Matched: “Fights COVID ”
  • BlockingCG-RFA-004Disease claims. Matched: “Fights COVID ”

What to say instead

This version came back with no rule fired:

Our zinc lozenge is a dietary supplement. Ask your doctor about vaccines and other ways to protect yourself.

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

What the rules themselves suggest:

  • CG-DIS-012 Remove the claim. Link to CDC or FDA guidance instead of making your own claim.
  • CG-DIS-016 Describe what the product contains or what the service involves and leave the disease outcome out. If a clinician treats the condition, say who, and that results vary by patient.
  • CG-RFA-001 Remove the disease claim. Describe only a lawful structure or function benefit and keep the disclaimer.

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-DIS-012 · Blocks approval · Citation checked against stored text

    Claims that a product prevents, treats or fights a virus or infection, including COVID-19, are disease claims. FDA and FTC have sent many warning letters on them.

    Source: FDCA 201(g)(1); 21 CFR 101.93(g); FTC Act section 5; FDA and FTC warning letters on unapproved COVID-19 products

    Safer wording: Remove the claim. Link to CDC or FDA guidance instead of making your own claim.

    21 CFR 101.93(g) · Needs counsel review

  2. CG-DIS-016 · Blocks approval · Citation checked against stored text

    A sentence that names a disease or condition and says it was cured, reversed, cleared, beaten, fixed or removed is a disease claim, however it is worded. For a product it makes the product an unapproved drug. For a service it needs substantiation and a statement of typical results.

    Source: FDCA 201(g)(1); 21 CFR 101.93(g); FTC Act section 5; FTC Health Products Compliance Guidance

    Safer wording: Describe what the product contains or what the service involves and leave the disease outcome out. If a clinician treats the condition, say who, and that results vary by patient.

    21 CFR 101.93(g) · Needs counsel review

  3. CG-RFA-001 · Blocks approval · Citation checked against stored text

    Saying a product cures, treats, prevents, relieves or fights a named disease or condition makes it an unapproved drug claim, and the FDA cites this wording in warning letters.

    Source: FDCA 201(g)(1); 21 CFR 101.93(g); FTC Health Products Compliance Guidance

    Safer wording: Remove the disease claim. Describe only a lawful structure or function benefit and keep the disclaimer.

    21 CFR 101.93(g) · Needs counsel review

  4. CG-RFA-004 · Blocks approval · Citation checked against stored text

    Claims to prevent, treat, detect or protect against COVID-19 or other viruses, or to sell an unauthorized test kit, are unapproved drug and device claims that the FDA and FTC have repeatedly enforced.

    Source: FDCA 201(g)(1); 21 CFR 101.93(g); FTC Health Products Compliance Guidance

    Safer wording: Remove the virus and COVID-19 claims. Link to CDC and FDA guidance instead.

    21 CFR 101.93(g) · Needs counsel review

Background: Disease claim in the glossary.

Questions

Which rule covers infectious disease claims?

Rule CG-DIS-012. It cites 21 CFR 101.93(g). The rule's reason: Claims that a product prevents, treats or fights a virus or infection, including COVID-19, are disease claims. FDA and FTC have sent many warning letters on them.

What should I write instead?

The rule's own suggestion for rule CG-DIS-012: Remove the claim. Link to CDC or FDA guidance instead of making your own claim.

Does the answer change for a drug, a supplement or a service?

Context changes the result. The same samples hit these blocking rules: 2 in a drug or device ad, 4 in a supplement ad, 2 in a clinical service ad. Pick the type that matches what you promote when you run the checker.

Next step

Check your own wording

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