BBB National Programs Archive


New York, NY – Jan. 25, 2012 -The National Advertising Division of the Council of Better Business

Bureaus has determined that Suncore Products, LLC, can support certain advertising claims for the

company’s  “WhoNu? Nutrition Rich Cookies.”

NAD, the advertising industry’s self-regulatory forum, requested substantiation for certain print,

internet and television claims made by the company, including:

• “As much Fiber as a bowl of oatmeal.”

• “As much Calcium and Vitamin D as an 8 oz. glass of milk.”

• “As much Vitamin C as a cup of blueberries.”

• “As much Iron as a cup of spinach.”

• “As much Vitamin E as two cups of carrot juice.”

• “As much Vitamin B12 as a cup of cottage cheese and fruit. “

• “As much Vitamin A as an 8oz. glass of tomato juice.”

• “Each delicious 3-cookie serving has 3 grams of Fiber, is an excellent source of Calcium, Iron,

Vitamins A, B12, C, D & E, and has a total of 20 essential vitamins and minerals.”

NAD also examined whether the advertising implied that eating a serving size of WhoNu? Cookies

was equivalent to consuming the benchmark foods – a cup of blueberries, a cup of spinach, a bowl

of oatmeal, a glass of milk, two cups of carrot juice, a cup of cottage cheese and an 8 oz. glass of

tomato juice.

In previous cases, NAD has expressed concern about advertising claims for snack foods that make

direct comparisons to whole fruits or vegetables.   In this case, NAD noted, the advertiser avoided

such comparisons and clearly limited its claims to the nutrition supplied by a vitamin or mineral.

Further, NAD noted, the advertiser refrained from expressly comparing WhoNu? cookies to whole

fruits and vegetables, did not depict actual foods on its labels but rather cartoonish sketches, did not

recommend its cookies as a substitute for healthy snacks, avoided making health claims and clearly

identified the nutrient in the food that was being compared to the advertiser’s product. Accordingly,

NAD determined that consumers would not take away the message that a serving of WhoNu?

cookies would provide the nutritional equivalence of each of the benchmark foods depicted. NAD

found the advertiser could support the claims at issue.

Suncore, in its advertiser’s statement, said the company “supports NAD’s self-regulation efforts and

appreciates its careful consideration of this matter.”



NAD’s inquiry was conducted under NAD/CARU/NARB Procedures for the Voluntary Self-Regulation of National Advertising.  Details of the initial inquiry, NAD’s decision, and the advertiser’s response will be included in the next NAD/CARU Case Report.

About Advertising Industry Self-Regulation: The National Advertising Review Council (NARC) was formed in 1971. NARC establishes the policies and procedures for the National Advertising Division (NAD) of the Council of Better Business Bureaus, the CBBB’s Children’s Advertising Review Unit (CARU), the National Advertising Review Board (NARB) and the Electronic Retailing Self-Regulation Program (ERSP).

The NARC Board of Directors is composed of representatives of the American Advertising Federation, Inc. (AAF), American Association of Advertising Agencies, Inc., (AAAA),  the Association of National Advertisers, Inc. (ANA), Council of Better Business Bureaus, Inc. (CBBB), Direct Marketing Association (DMA), Electronic Retailing Association (ERA) and Interactive Advertising Bureau (IAB).  Its purpose is to foster truth and accuracy in national advertising through voluntary self-regulation.

NAD, CARU and ERSP are the investigative arms of the advertising industry’s voluntary self-regulation  program. Their casework results from competitive challenges from other advertisers, and also from self-monitoring traditional and new media. NARB, the appeals body, is a peer group from which ad-hoc panels are selected to adjudicate NAD/CARU cases that are not resolved at the NAD/CARU level. This unique, self-regulatory system is funded entirely by the business community; CARU is financed by the children’s advertising industry, while NAD/NARC/NARB’s primary source of funding is derived from membership fees paid to the CBBB. ERSP’s funding is derived from membership in the Electronic Retailing Association. For more information about advertising industry self-regulation, please visit