A research-use-only product page should read like a listing in a laboratory supply catalog. It says what the material is, how it is supplied, how it was tested and how it should be stored. It does not read like a consumer product page. If a reader could reasonably take the page as an offer to the public for personal use, a "research use only" line at the bottom does little to change that impression.
Use the checklist below on every product page in your store. Work through what the page should contain, then what it should not contain, then the parts of a page that are easy to forget: images, reviews, related products and metadata.
Why the whole page matters, not just the label
Labels are read in context. 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 decide a product's intended use from other evidence, including how it is marketed. FDA's regulation on the meaning of intended uses for drugs, 21 CFR 201.128, describes intent as objective and says it can be shown by labeling claims, advertising matter, oral or written statements and the circumstances of sale.
Stripe also reviews business websites. Its website checklist asks businesses to describe clearly what they sell, and says that if Stripe reviews a site and finds this unclear, it may contact the business with recommendations. A page that is specific and accurate is easier for anyone to assess. For more on the label itself, see what research use only means, and what it does not.
What the page should contain
- An exact product name that identifies the material. Avoid nicknames, slang or brand-style names that suggest a personal use.
- Identity details, such as the chemical name, CAS number where one exists, molecular formula or sequence, and your catalog or SKU number.
- Form and quantity per unit, for example the physical form and the amount in each container, in the units a laboratory would use.
- Purity and test method: the figure you can support with a document, and the method used to measure it.
- The certificate of analysis for the current lot, or a clear note on how a buyer can request it. See what a certificate of analysis should show.
- Storage and handling conditions for the material as shipped, such as temperature and protection from light or moisture.
- A plain intended-use statement, for example "For laboratory research use only. Not for human or animal use."
- Who you sell to, for example "Sold only to qualified business and research buyers," with a link to the page that explains your buyer requirements.
- Price and currency. Stripe's checklist notes that a currency symbol alone may not be enough for international buyers.
- Links to your policies: shipping, refunds and returns, and terms of sale.
What the page should not contain
- Any statement about what the material does in a person or an animal, including effects, benefits, results or side effects.
- Amounts, schedules, mixing or preparation instructions, or anything else framed around personal use.
- Health, wellness, fitness, weight, appearance, sexual or performance claims, whether stated directly or suggested by images, product names or category names.
- Customer reviews, questions or testimonials that describe personal use.
- Comparisons to medicines or prescription products, or references to drug brand names.
- Before-and-after images, body imagery or lifestyle photography.
- A "research use only" line placed next to copy that plainly speaks to consumers.
That last point is worth spelling out. The FTC's health products guidance says a disclaimer will not cure an otherwise deceptive ad, and that a disclosure cannot directly contradict the claim it sits beside. The same guidance says marketers are responsible for claims that are suggested or reasonably implied, and that the test is how consumers understand the ad, not what the marketer intended. A product name, a photo or a category label can carry an implied claim as easily as a sentence can. The full list is in claims to remove from a research supply store.
The parts of a page that are easy to forget
- Images. Product photos should show the container and its label. Check image alt text and file names too, since both are part of the page.
- Category and tag names. A category named after a personal goal rather than a material type attaches that goal to every product inside it.
- Related products and bundles. Bundles or "frequently bought together" panels grouped around a personal outcome suggest a use the rest of the page does not make.
- Reviews and questions. Review and Q&A sections belong to the page. Moderate them against a written rule that applies to positive and negative posts alike.
- SEO titles, meta descriptions and structured data. These are written separately from the visible page and are often left over from older copy.
- Downloads and inserts. PDFs, label images and package inserts should say the same thing as the page. See keeping labels and packaging consistent with your site.
- Old URLs. A renamed product may still be reachable at its old address with its old copy. Redirect old URLs to the current page or remove them.
A quick test for each page
- Read the page as a stranger would. Could someone reasonably think the product is for personal use?
- Check that every figure on the page, such as purity, quantity and lot number, matches the current certificate and label.
- Search the page text, image text and metadata for words that refer to people, bodies or personal outcomes, and rewrite or remove each one.
- Confirm the intended-use statement and the buyer statement sit near the price and the add-to-cart button, not only in a footer.
- Open each policy link and confirm it leads to the current version of the policy.
- Note the date you reviewed the page, who reviewed it and what you changed.
What this checklist cannot do
A clean product page is one part of a compliance program, not the whole of it. It does not tell you who is buying, it does not decide whether your products can be sold where you sell them, and it does not decide how a payment processor will view your business. Stripe and the card networks make their own decisions. In the same RUO guidance, FDA also notes, for diagnostic products, that a buyer certification program alone does not relieve a manufacturer of its responsibility to keep labeling and distribution consistent with the label. Speak to a qualified lawyer about your specific products and markets.
Pages also drift as people edit them, so a page that passed this checklist last quarter may not pass it today. A weekly storefront monitoring routine helps catch changes. Claddr checks product pages, policies and checkout copy against your compliance profile each week and reports each finding with the exact line and a suggested fix. You decide what to change. See how Claddr works.
Sources
- 01FDA: 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
- 02GovInfo: 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
- 03Stripe Docs: Website checklistdocs.stripe.com/get-started/checklist/website
- 04FTC: Health Products Compliance Guidancewww.ftc.gov/business-guidance/resources/health-products-compliance-guidance