If your store sells research-use-only products to business and research buyers, some content does not belong anywhere on it: claims about health or performance, anything about using the products on people or animals, testimonials about personal use, and comparisons with medicines. Remove it outright. A disclaimer placed next to it does not cancel it out, and a "research use only" label does not turn consumer copy into laboratory copy.
Work through the checklist below across product pages, category pages, the blog, FAQs, emails, social profiles and anything else you publish. The aim is a store where every page describes materials, not outcomes.
Why a disclaimer does not cancel a claim
The FTC's health products guidance says a disclaimer will not cure an otherwise deceptive ad, that a disclosure cannot directly contradict the claim it accompanies, and that vague qualifying terms are not enough. It also says the test is how consumers understand the ad, not what the marketer intended, and that marketers are responsible for claims that are reasonably implied as well as those stated outright.
FDA takes a similar view of labels. In its guidance on in vitro diagnostic products labeled for research use only, FDA says that placing an RUO label on a product does not by itself exempt it from other requirements, and that the agency may look at other evidence, including how the product is marketed. That guidance is written for diagnostic products, but its reasoning about labels and other evidence is a useful reference. FDA's regulation on intended uses for drugs, 21 CFR 201.128, lists labeling claims, advertising matter and oral or written statements as ways intent can be shown. Put simply: what the rest of the page says counts. See intended use, and why a label is not enough. For how any of this applies to your products, speak to a qualified lawyer.
The checklist
Health, wellness and performance claims
- Claims about treating, preventing or easing any disease or condition.
- Weight-loss, muscle-building, fitness, recovery, sleep, energy or focus claims.
- Anti-aging, skin, hair, tanning or other appearance claims.
- Sexual health or libido claims.
- Claims about mood, wellbeing or how someone will feel.
- Implied versions of all of the above: product names, category names, hashtags, icons or images that suggest one of these outcomes without saying it.
Content about use on people or animals
- Amounts, schedules, frequencies or durations framed around a person or an animal.
- Mixing or preparation instructions written for personal use, and calculators or charts that support them.
- Descriptions of how to take or give a product, or what equipment to use for that.
- Descriptions of what a compound does in a body, including mechanisms written for a general audience.
- Side effect lists, warnings framed around personal use, or "what to expect" content.
Testimonials, reviews and endorsements
- Customer reviews or testimonials that describe personal use or personal results.
- Before-and-after photos, progress pictures and body imagery.
- Quotes from coaches, clinicians, athletes or influencers about results.
- Star ratings or review snippets in search markup that repeat any of the above.
Testimonials are claims in their own right. The FTC's Endorsement Guides, 16 CFR Part 255, say advertisers can be liable for misleading or unsubstantiated statements made through endorsements, and that consumer endorsements are not competent and reliable scientific evidence. The FTC's health products guidance adds that anecdotes are never sufficient to substantiate claims about the effects of a health product. Moderate reviews against a written rule that applies the same way to positive and negative posts.
Comparisons with medicines
- Comparisons with prescription drugs, approved medicines or named drug brands.
- Phrases such as "alternative to," "like" or "same as" followed by a medicine.
- Price comparisons against pharmacy or prescription costs.
- Links to articles about medicines placed beside your products.
Outside research used to sell
- Summaries of studies about effects in people or animals placed on product pages.
- Links from product pages to outcome research, forums or community threads about personal use.
- Quotes pulled from abstracts and presented next to a buy button.
The FTC's health products guidance specifically addresses the use of articles, study abstracts and other third-party literature to promote a particular brand. If you want to show technical data, show identity and quality data about the material you sell.
Signals that you are selling to consumers
- "No prescription needed," "no questions asked" or similar lines.
- Copy addressed to a general audience, such as "for anyone looking to."
- Shipping copy that stresses discreet packaging for personal orders.
- Promotions tied to personal goals or consumer holidays. See discount codes and promotions in a regulated store.
- Affiliate or influencer content aimed at consumers. See affiliate and influencer programs for research suppliers.
Removing claims properly
Removing a claim means deleting it, not hiding it. A few points to get right:
- Delete, then redirect. Remove the content and redirect the old URL to a relevant current page, or let it return a not-found response. Take it out of your sitemap.
- Check every copy. Claims live in metadata, image alt text, PDFs, email templates, cached feeds for marketplaces and social bios.
- Do not move claims somewhere less visible. Putting claims behind a login, inside images, on a separate site or in private messages does not remove them. Doing that to keep them away from a reviewer is concealment, and it is not something to do.
- Rewrite rather than soften. Replacing a claim with a hedged version of the same claim leaves the claim in place.
- Keep a record. Note what you removed, where it was, when and who approved the change.
For older articles, use auditing old blog posts before a processor review.
What this checklist cannot do
Removing claims is necessary, but it is not the same as being an appropriate business for a given processor. Stripe and the card networks make their own decisions, and a clean store does not guarantee any outcome. It also does not tell you whether your products can be sold where you sell them; that is a question for a qualified lawyer. Claims also creep back as pages are edited. Claddr's weekly monitoring checks product pages, policies and checkout copy against your compliance profile and points to the exact line with a suggested fix. See how Claddr works.
Sources
- 01FTC: Health Products Compliance Guidancewww.ftc.gov/business-guidance/resources/health-products-compliance-guidance
- 02GovInfo: 16 CFR Part 255 (2024 edition), Guides Concerning the Use of Endorsements and Testimonials in Advertisingwww.govinfo.gov/content/pkg/CFR-2024-title16-vol1/xml/CFR-2024-title16-vol1-part255.xml
- 03FDA: Distribution of In Vitro Diagnostic Products Labeled for Research Use Only or Investigational Use Only (guidance)www.fda.gov/regulatory-information/search-fda-guidance-documents/distribution-in-vitro-diagnostic-products-labeled-research-use-only-or-investigational-use-only
- 04GovInfo: 21 CFR 201.128 (2024 edition), Meaning of "intended uses"www.govinfo.gov/content/pkg/CFR-2024-title21-vol4/xml/CFR-2024-title21-vol4-sec201-128.xml