Where the line sits on a product page
The one distinction that drives everything
A product becomes a drug, in the law's eyes, the moment its marketing says it treats, cures, mitigates, or prevents a disease. Not because of what's in the bottle — because of what the page says. That's why two companies can sell a similar formula and only one gets a warning letter: the difference was the copy. For supplements, the lawful lane is what the statute calls structure/function language — describing effects on the body's normal structure or function ("supports a healthy immune response") rather than on a disease ("shortens the flu"). Topicals and cosmetics have their own narrower lanes. The lanes are real, but they're category-specific — which is exactly the call your counsel makes.
"Supports" is not a costume
The most common remediation mistake is dressing a disease claim in softer verbs: "supports recovery from the flu" is still a flu claim. The agency reads the sentence for what it communicates, not for its verb choice. If the noun is a disease — the flu, eczema, arthritis — no amount of "helps," "supports," or "may assist with" moves the sentence into the lawful lane. The honest rewrite changes what the sentence is about, or the sentence goes.
Claims hide outside the paragraph
Warning letters quote more than body copy, and a remediation has to cover everything the letters cover:
- Product names. A product name that contains the disease it promises to treat is itself a treatment claim; renaming is sometimes the only real fix.
- Images. Before/after photos of a skin condition, packaging renders with disease names, infographic captions — FDA quotes imagery routinely.
- Testimonials and reviews you feature. "This cleared my eczema in a week" on your page is your claim, even though a customer wrote it.
- Metadata. Page titles, meta descriptions, and alt text are indexed, displayed, and quoted in letters like any other copy.
- Marketplace listings. Your Amazon listing is your marketing. Letters cite them side by side with the site.
What the rewrite actually looks like
For each quoted claim the inventory records one of two directions: rewrite — there's a lawful way to describe this product's purpose, and here it is — or remove — there isn't, and the claim comes out along with the imagery and testimonials that carry the same message. Then the same decision gets applied everywhere the pattern repeats, because the quoted URLs are examples, not the full list. The finished state is a page that sells the product on what it lawfully is — and a correction log proving the change, line by line.
Contact
Email [email protected]. You'll get a reply from me — usually the same day, always from a person.