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Can I say it?

Can I say “zero risk” in a clinic 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-EFF-013. Its reason: Saying a treatment or product is completely safe or has no side effects is a safety absolute that cannot be substantiated and hides real risks.

Source the rule cites: FTC Act section 5; FTC Health Products Compliance Guidance; FDCA 502(n) (risk information in drug advertising)

Checked as an ad promoting a clinical service. Context changes the result. The same samples hit these blocking rules: 2 in a drug or device ad, 2 in a supplement ad, 1 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

Zero risk of complications.

  • BlockingCG-EFF-013Efficacy and proof. Matched: “Zero risk”
  • WarningCG-ABS-012Absolute promises. Matched: “Zero risk”
  • WarningCG-TRC-011Absolute promises. Matched: “Zero risk”
  • WarningCG-TRK-009Absolute promises. Matched: “Zero risk”
Sample 2 · actual checker output4 rules fired

Zero risk, zero pain, zero downtime.

  • BlockingCG-EFF-013Efficacy and proof. Matched: “Zero risk”
  • WarningCG-ABS-012Absolute promises. Matched: “Zero risk”, “zero pain”, “zero downtime”
  • WarningCG-TRC-011Absolute promises. Matched: “Zero risk”
  • WarningCG-TRK-009Absolute promises. Matched: “Zero risk”, “zero pain”, “zero downtime”
Sample 3 · actual checker output4 rules fired

Our surgery has zero risk for healthy adults.

  • BlockingCG-EFF-013Efficacy and proof. Matched: “zero risk”
  • WarningCG-ABS-012Absolute promises. Matched: “zero risk”
  • WarningCG-TRC-011Absolute promises. Matched: “zero risk”
  • WarningCG-TRK-009Absolute promises. Matched: “has zero risk”

What to say instead

This version came back with no rule fired:

We will go over the possible complications at your consult, and you decide with your surgeon whether it is right for you.

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

What the rules themselves suggest:

  • CG-EFF-013 Remove safety absolutes. Describe known risks and who should not use the product.
  • CG-ABS-012 Describe the known risks and side effects, or say where they are explained, in place of claiming there are none.
  • CG-TRC-011 Describe real risks and recovery times, cite your complication rate if you have data, and avoid words like zero, never or safest.

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-EFF-013 · Blocks approval

    Saying a treatment or product is completely safe or has no side effects is a safety absolute that cannot be substantiated and hides real risks.

    Source: FTC Act section 5; FTC Health Products Compliance Guidance; FDCA 502(n) (risk information in drug advertising)

    Safer wording: Remove safety absolutes. Describe known risks and who should not use the product.

    See source text · Needs counsel review

  2. CG-ABS-012 · Blocks approval · Citation checked against stored text

    Zero-risk, zero-pain and no-downside claims are absolute safety claims. Every treatment has risks, and they must be disclosed fairly.

    Source: FTC Act section 5; FTC Health Products Compliance Guidance; 21 CFR 202.1

    Safer wording: Describe the known risks and side effects, or say where they are explained, in place of claiming there are none.

    21 CFR 202.1 · Needs counsel review

  3. CG-TRC-011 · Warns

    Claiming no complications, no side effects or no risk is a false safety guarantee; every procedure and drug carries risk and unsupported safety claims are deceptive.

    Source: FTC Act section 5 and FTC Policy Statement on Deception; FTC Health Products Compliance Guidance (substantiation); state medical board advertising rules

    Safer wording: Describe real risks and recovery times, cite your complication rate if you have data, and avoid words like zero, never or safest.

    See source text · Needs counsel review

  4. CG-TRK-009 · Warns

    Absolute safety claims such as no hospital visits, no risk or zero recovery cannot be substantiated for medical procedures or hormone products and hide real adverse-event risk.

    Source: FTC Act section 5 and FTC Health Products Compliance Guidance (2022) on substantiation; FDA position on compounded bioidentical hormones; 21 USC 352(a)

    Safer wording: Remove absolutes. State known risks and side effects in plain terms and avoid claiming safety over approved options.

    See source text · Needs counsel review

Background: Clear and conspicuous in the glossary.

Questions

Which rule covers zero-risk claims?

Rule CG-EFF-013. The rule's reason: Saying a treatment or product is completely safe or has no side effects is a safety absolute that cannot be substantiated and hides real risks.

What should I write instead?

The rule's own suggestion for rule CG-EFF-013: Remove safety absolutes. Describe known risks and who should not use the product.

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, 2 in a supplement ad, 1 in a clinical service ad. Pick the type that matches what you promote when you run the checker.

Next step

Check your own wording

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