We all use testimonials, but we should all make sure we are using FDA compliant testimonials. The FDA is still working on CBD and it efficacy and dangers. They haven’t really classified it or regulated yet. Thar doesn’t stop them from regulating what we do,
The issue is that anything that affiliates or salespeople say affects the parent company that they represent. What you say can dramatically hurt the company you are working with unless you use compliant testimonials.
No Healing. Curing or Treating
Here is what we know. If you are sharing information about CBD, you need to be very careful not to claim that it “Cures” , “Prevents”, “Treats”, or “Heals.”
Restricted Symptoms
You also cannot reference disease names (e.g. anxiety, cancer, depression) or use symptoms like “pain.”
You Can Be Held Responsible
The FDA is very clear that as soon as you copy or reference something that is non-compliant, then you are non-compliant.
In addition to testimonials, you also cannot quote from published works if the quote contains forbidden words or phrases. Even though the author said something, when you quote it, it is as if you said it yourself.
You should not use non-compliant testimonials, even is private Facebook Groups or emails.
No Guarantee
Before I continue, let me be very clear. I am NOT a lawyers, nor has anything I’m saying here been reviewed or approved by the FDA. I am doing my best to make sure we are all compliant with regulations, but I cannot guarantee anything, so use at your own risk.
The Solution for Compliant Testimonials
The solution is to replace replace words that can’t be used and replace them with phrases that can be used. For example, if someone says they saw a reduction in their pain, you can replace the word “pain” with [discomfort”]*.
The brackets indicate the portion of the testimonial you modified. The asterisk indicates there will be a note at the bottom of the testimonial. In that note you say something like “Modified to comply with FDA regulations”.
Following that note you should include a disclaimer like the following “
Disclaimer:
“Statements made on this product or website have not been evaluated by the Food and Drug Administration. These products are not intended to diagnose, treat, cure, or prevent any disease. These products are NOT intended to replace medications or eliminate the advice of a competent health care practitioner.”
List of Words and Suggested Replacements
Here is a link to a Google Doc with words you are not allowed to you and suggested replacements to help you create compliant testimonials: Link to Shared Doc
I’ll be adding new words and new suggested replacements as time goes on.
/BTW Here is a post about an test editor you can use to edit compliant testimonials and KEEP the Facebook emojis. And another post that talks about how to put a compelling testimonial together.
Until Next Time. Remember, You Are One Decision Away…! Oh Hale Yes
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