In today’s modern times dietary supplement marketing materials can come in a variety of forms, including blogs, Tweets, Facebook, StumbleUpon, Google+, reddit, Testimonials, Websites and Links. However, it is important to be aware that the FDA and FTC are monitoring all forms of your advertising and promotional materials, and you must as well, or run the risk of receiving a Warning Letter.

Dietary Supplement Marketing: If You Control the Content, You are Responsible For It.

With Forbes writing articles like the one from May 1, 2013 entitled, “How To Triple Your Success Using Social Media Advertising Platforms,” it’s no wonder nutraceutical companies are using social media as tool for dietary supplement marketing to promote their products. However, it is imperative that companies have a policy in place to monitor all forms of social media. Otherwise, you may wind up with a Warning Letter from the FDA stating that your products are drugs and illegal to be sold. In the Warning Letter, the FDA will further advise that if the violations are not promptly corrected, you may face regulatory action without further notice, such as seizure and/or injunction.

Dietary Supplement Marketing: Be Sure You Are Not Endorsing Disease Claims Made By Others.

There has been a rash of Warning Letters recently issued by the FDA finding that claims made through social media cause products intended to be dietary supplements to be drugs. For example, Warning Letters have stated that articles found by following a link from a company’s website established that the product is a drug because the implication could be made from the article that the product is intended for use in the cure, mitigation, treatment, or prevention of disease. Other Warning Letters stated that by “liking”, sharing or retweeting a comment that makes a disease claim the company is adopting that claim. By doing so, the products will be considered by the FDA to be unapproved new drugs. Ignorance by management that the social media department or one of its employee is out there liking and retweeting customers disease claims is no defense. It bears repeating to be sure to have policies and procedures in place to oversee the promotion and marketing of your products through social media.

dicentra will review your social media strategy, policies promotional and advertising materials and provide guidance and solutions to avoid your products being construed as drugs and ensure that you avoid the unwanted attention of the FDA or the FTC.