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MLM Company Cited For Claims Made By Their Affiliates

Companies that compensate influencers or affiliates may be responsible for claims they make

MLM Company Cited For Claims Made By Their Affiliates

This is the one-year anniversary of #WarningLetterWednesday. I have written this post every week, even when having Covid, on a tropical vacation, or under a massive work deadline. I love writing this post and hope you find as much joy in it as I do.

Today’s post is unique. It involves an MLM company that was cited for claims made by company “consultants,” which is very similar to influencers or affiliates that receive compensation for referral sales to a company website. This is the first time I have seen a company cited for claims made by its affiliates, and this is a trend to watch.

From warning letter: “Consumers interested in your products are then redirected by your consultants to your websites and to purchase your products.”

One of the affiliate Instagram pages mentioned in this letter only has 627 followers, a good reminder there is no such thing as being too small to attract FDA scrutiny.

Most claims cited in the warning letters are from the “consultants,” with a few exceptions such as this.

From warning letter: “On your website, studies suggest [t]he most common illnesses caused by an improperly functioning ECS are depression, Alzheimer[’]s, IBS, fibromyalgia, and even migraines”

The Denver office issued this warning letter, which seems to be more rigid with online claims enforcement than other divisions or the national offices.

Key takeaways are companies should remove risky words from company websites and train and monitor affiliates and influencers to ensure no disease claims are present. I look forward to hearing your comments on this very fascinating warning letter!

Full warning letter

Disclaimer: The educational information provided here is for informational purposes only. Contact an attorney for specific legal advice. Rule #1 in compliance is to ensure marketing is truthful and not misleading.

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