Warning Letter Wednesday

Learn from other’s mistakes

Learn from other’s mistakes

Distributors must comply with some GMP requirements

Do's and don'ts of puffery

Implied marketing statements should be compliant

Product tags are marketing claims

Review old social posts for regulatory “landmines”

Influencers must disclose material connection

All marketing is “labeling”

We can learn a lot from NAD cases

Old posts are "active" marketing

Clinical study parameters must match claims

Inflammation + arthritis claims = warning letter

Distributors are responsible for products they sell

Formats that are favorable to children should be avoided

Re-review online marketing after FDA inspection

Review old social posts

Advisory labeling is not a replacement for allergen control program

Arthritis claims attract scrutiny

Websites are considered “labeling”

Old blogs & posts are “active” marketing

Review old videos for compliance

Companies are responsible for co-manufactured products

Minor violations can signal the authorities