Product Tags & Metatags Attract FDA Attention
Everything used to market products must be compliant
Website product tags and metatags continue to attract FDA attention in warning letters. #WarningLetterWednesday
This year three warning letters mention product tags or “category” tags. These tags help people find products when they search for things on Google or a website, and they are considered marketing in the eyes of the FDA and FTC.
Although these tags are an “extension of the label,” they are not likely to attract a warning letter on their own. However, they signal intended use, which can lead authorities to a commercial website to keep digging for claims once there.
Here are some examples involving product tags and metatags with disease claims. It's worth noting that additional high-risk website and social media claims are also present in each warning letter. This is an important reminder that compliance is not done in a vacuum, and all online content must be free of high-risk claims to avoid warning letters.
From Warning Letter: “From the product webpage at …. Tags: anxiety, . . . memory, mental performance, natural depression remedy”
From Warning Letter: “Tags: anti-viral, COVID, COVID-19, Cure”
From Warning Letter: “The above noted website claims are supplemented by metatags used to bring consumers to your website ….. through Internet searches. The metatags are: • “Take Altitude RX for altitude sickness prevention…”
Read this warning letter here:
Here is my “All Marketing is Labeling” video.
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.