Hand the client proof the copy was reviewed.

Our stem cell shot cures arthritis. 100% guaranteed. Book this week.

• Blocks approvalCG-RFA-001Also matches CG-TRA-001, CG-TRI-001, CG-TRK-004, CG-DIS-001, CG-DIS-016, CG-DIS-018, CG-PLT-013, CG-PLT-035

  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.

• Blocks approvalCG-ABS-002

  A 100 percent claim is an absolute claim that almost never has support.

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

  Safer wording. Replace with the measured figure and its source, or remove the number.

• WarningCG-ABS-001

  Outcome guarantees are unsubstantiated absolute claims.

  Source. FTC Act section 5, 15 U.S.C. 45; FTC Health Products Compliance Guidance

  Safer wording. Remove the guarantee. If you offer a refund policy, describe the policy ("30-day refund if you are not satisfied") instead of guaranteeing results.

"I was diagnosed with diabetes in 2019. After three months with Dr. Lee's program my A1C was normal and I stopped my insulin." Results are typical.

• Blocks approvalCG-TRH-003

  Patient stories claiming a product or clinic cured cancer, reversed diabetes, dissolved tumors or let the patient drop prescriptions make unapproved disease-treatment claims and can lead consumers to stop necessary medication.

  Source. FTC Endorsement Guides, 16 CFR 255.2 and 255.1(a); FTC Act section 5; FDCA section 201(g) (disease claims make a product an unapproved drug)

  Safer wording. Do not publish or share stories of cures, dropped medications or disappeared tumors. Use only substantiated outcomes with a clear disclosure of typical results, and never suggest stopping prescribed treatment.

• Blocks approvalCG-RPL-007Also matches CG-TRG-001, CG-RPL-004

  Telling people to stop, skip or replace prescribed medication, screening or emergency care is dangerous and is a claim that a product works in place of medical care.

  Source. FTC Act section 5; FTC Health Products Compliance Guidance; FDCA 201(g)

  Safer wording. Say nothing about stopping or replacing medication or screening. Tell people to talk to their clinician before changing treatment.

• WarningCG-DIS-017Also matches CG-DIS-022, CG-TES-002

  A device, test or service that claims to diagnose or detect disease makes the product a regulated medical device or test, and detection claims need clearance and evidence.

  Source. FDCA 201(h); FDA Clinical Decision Support and Software as a Medical Device guidance

  Safer wording. Remove detection or diagnosis claims unless the product is cleared for them, and say that a licensed clinician makes diagnoses.

Tired of chemo side effects? Ask your doctor about Zelvora, the best treatment for lung cancer.

• Blocks approvalCG-TRA-011

  Branded prescription drug ads that name the drug and a benefit without the required risk information and fair balance, or that say side effects are rare, are misbranding.

  Source. FDCA 502(n); 21 CFR 202.1 (prescription drug advertising, fair balance); FTC Act section 5

  Safer wording. Include the major risks and indications as required for prescription drug advertising, and do not downplay side effects.

• Blocks approvalCG-DIS-002Also matches CG-SUP-004

  A treatment claim for a named disease is a drug claim for a product, and needs support for a clinical service.

  Source. FDCA 201(g)(1); 21 CFR 101.93(g); FTC Act section 5

  Safer wording. For a clinical service, state who delivers care and what is offered ("our licensed clinicians evaluate and manage ..."). For a supplement, remove the disease reference.