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member memos

UNPA / FTC Warning Letters; Coronavirus Round 4 -- UNPA Analysis

5/21/2020

 
Dear Colleagues,

As Danielle Masterson reported in yesterday's NutraIngredientsOnline (May 18, 2020), the FTC has issued a fourth round of warning letters to firms making unlawful COVID-19 claims.

UNPA decided to take a closer look at the who, how and what products are behind these warning letters. We now share our findings.
  1. Who?  The large majority of warning letter recipients are some type of "clinic" or practitioner-based service. Many feature TCM, acupuncture, wellness and holistic health backgrounds. Few, if any, are retail stores, and few are classic dietary supplement purveyors.

  2. How?  Many of these firms use their company websites to promote the challenged claims, but Facebook is clearly where the action was taking place. Facebook in particular, but also other social media platforms, have all become major hubs for COVID-19-related communications, some of it unlawful. Radio interviews also featured in a few of these cases.

  3. What products?  
    1. There is an interesting mix of products and treatments. By far the most important is high dose vitamin C IVs with reference to two studies in China, using vitamin C IV treatments on Chinese COVID-19 patients. MedicineNet, a widely followed online service that tracks early clinical studies published in the global literature, notes this study from Wuhan. Many warning letter recipients make reference to this study and now offer similar treatments
    2. TCM herbs, oregano oil, black seed oil, colloidal and nano silver, elderberry, ozone treatment, and the Photon Genius Machine (which is a real thing -- and available on Ebay for $18,500) also featured among the warning letters.

Where is all of this happening? All over the country. No regionality is evident.

From mid- to late-March through the present, there have been a growing number of articles appearing in the grocery store check-out stand genre of news. See this article from the New York Post regarding Christine Cuomo's Coronavirus remedies which resemble the products/services seen in the warning letters.

Yesterday, Senator Chuck Schumer issued a video statement calling for more aggressive action to crack down on such scammers, on the view that FTC warning letters, important as they are, are not adequate to stand down the growing number of promoters of treatments and products to frightened people who are both vulnerable and desperate for the "miracle cure."

OUR TAKEAWAY:  90 days+ into the pandemic, a familiar pattern has emerged which suggests aggressive practitioners (who seem to be out on the fringe end of the spectrum), citing largely unverified studies or testimonials, are using the megaphone of Facebook and other social media to promote a combination of both well-respected dietary supplements, along with a range of very edgy treatments and TCM herbs as treatment breakthroughs for COVID-19. While we have not reviewed the previous three rounds of FTC warning letters (which we will do), our present view is that this is likely the front end of a growing wave of unlawful and inappropriate claims that will continue, despite warning letters or other more aggressive regulatory actions.

We know, based on long experience, that in times of health crisis there always have been (and likely always will be) the clueless, the exploitive, in addition to the well-meaning and sincere "no one can tell me what to say" communities who become very active and always trigger a strong response from regulators. This conflict has long been a root cause of discussion and dissension about the legitimacy of the dietary supplement and natural health product industries.

We also recognize the hard task of nurturing and promoting new and interesting ideas and products while still abiding by the rules of the game. At no time in our experience have the stakes been higher, and therefore the need to be equally vigilant in holding the line against predatory claims and protecting highly vulnerable populations from physical and economic harm. That said, we also hope that this terrible pandemic will spur new and creative thought and investigation into the role and value of nutrition, personalized medicine and the natural healing arts.

Stay safe, stay well, stay vigilant.

LDI

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