Rule CG-RAF-010
Efficacy and proof: what rule CG-RAF-010 checks
Rule CG-RAF-010 is one of the checker's efficacy and proof rules. It cites 21 CFR 101.93(g). The reason, source and safer wording are below.
CG-RAF-010 · Warns · Citation checked against stored text
Saying a product boosts or strengthens the immune system or protects against colds, flu or infection implies prevention of disease, which is not an allowed structure or function claim without evidence.
Source: FTC Act section 5 and FTC warning letters on immune and COVID-19 claims; 21 CFR 101.93(g). UK ASA rulings are the origin of the pattern but UK law is out of scope.
Safer wording: Use only supported structure and function wording such as supports immune health, add the standard disclaimer, and never imply disease prevention.
21 CFR 101.93(g) · Needs counsel review
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