What Substantiation Does a Company Need to Support its Claims?
Look at your advertising to determine what objective claims you are making. At minimum, the level of proof it says it has. The FTC Policy Statement Regarding Advertising Substantiation makes that clear: “When the substantiation claim is express (e.g., tests prove, doctors recommend, and studies show), the Commission expects the marketer to have at least the advertised level of substantiation.” So if you say your claims are “clinically proven,” you must have clinical trials.
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