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Pressing issueStudy population matters: Looking at ashwagandha Randomized Controlled Trials (RCTs), NAD determined that one of the trials was insufficient for substantiation, since the study group was perimenopausal women, and the product is not specifically marketed toward women in this group.
Attributing benefits to ingredients is a “safer” strategy. Asa explained: “It’s ‘common-ish knowledge’ in certain regulatory circles that attributing benefits to ingredients rather than to the entire product may lessen the need for a product RCT. This can also help reduce litigation risk. What is odd is that Example #37 in FTC’s Health Products Compliance Guide seems to suggest that ingredient studies may not be enough. This got me thinking about context and the reasonable consumer takeaway. The theme is CONTEXT MATTERS, so reviewing the entire advertisement rather than just a specific claim is essential.
Read the NAD case, and connect with Asa on LinkedIn for more regulatory updates and insights!


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