NAD further recommended that the advertiser discontinue its use of testimonials claiming that Synaptol treats ADD/ADHD symptoms or that is can be used as a replacement for or alternative to prescription treatments for ADD/ADHD.
NAD is an investigative unit of the advertising industry’s system of self-regulation, which is administered by the Council of Better Business Bureaus.
As an initial matter, Hello Life notified NAD in writing that it had voluntarily discontinued several claims for its Synaptol product including claims that it “quickly” relieves ADD/ADHD symptoms, provides “fast” relief, and is “non-addictive.” It further discontinued its claim that Synaptol supports “energy, vibrancy and a fresh approach to life” and is “bio-available.” It also discontinued the claims, “What happens when you and your family choose Synaptol for ADD/ADHD symptom relief? You can relax and enjoy a true, healthy return to daily wellness!” and “By taking Synaptol just twice a day, you can naturally help free yourself from ADD/ADHD symptoms, by helping your body and mind to regain control, and allowing you to restore the productive, healthy lifestyle you desire.”
The advertiser contended that the remaining claims for Synaptol are substantiated by competent and reliable scientific evidence. HelloLife submitted provings found in A Dictionary of Practical MateriaMedica, by John Henry Clarke, M.D. and Materia Medica with Reperatory by William Boericke, M.D. and the Homeopathic Pharmacopeia of the United States (HPUS) as support for its Synaptol product claims.
It contended that these texts meet the FTC definition of competent and reliable scientific evidence as “other evidence based upon the expertise of professionals in the relevant area.” Hello Life further noted that HPUS and Materia Medica are explicitly recognized by the Food and Drug Administration (FDA) in its Compliance Policy Guide.
NAD has reviewed advertising claims made for homeopathic products in multiple prior proceedings. In general, in order for the advertiser of a homeopathic product to support claims that its product can treat a specific health condition or was effective at relieving specific symptoms, NAD has required support beyond homeopathic provings, including competent and reliable scientific testing on the product itself.
In this case, the advertiser provided no support beyond homeopathic provings and no support for its claims that the product as formulated relieves ADD/ADHD symptoms. NAD recommended that the advertiser discontinue any claims that Synaptol treats or relieves the symptoms of ADD/ADHD.
NAD further recommended that the advertiser discontinue its use of consumer testimonials that state or suggest Synaptol treats ADD/ADHD symptoms or that the product can be used as a replacement for or alternative to prescription treatments for ADD/ADHD.
Hello Life, in its advertiser’s statement, said the company “provided NAD with volumes of Materia Medica substantiation, which is based upon the expertise of homeopathic professionals. The label also clearly discloses that indications are based on the homeopathic Materia Medica. While it believes that it has adequate substantiation, Hello Life, LLC will take into consideration NAD's decision as it reviews current and future advertising and labeling for the product.”