BBB National Programs Archive
NAD Recommends Cebria Discontinue Challenged Claims for Dietary Supplement Promoted as a Memory Protection Aid; Company to Appeal
New York, NY – Jan. 11, 2018 – The National Advertising Division has recommended that Cebria, the maker of Cebria dietary supplement, discontinue certain claims challenged by the Council for Responsible Nutrition, including broad and unqualified memory improvement claims.
NAD is an investigative unit of the advertising industry’s system of self-regulation and is administered by the Council of Better Business Bureaus.
NAD has a long history of protecting vulnerable audiences such as older Americans with memory complaints. In 2002, as part of its routine monitoring program, NAD investigated claims for Senior Moment Advance Memory Enhancing dietary supplements, concluding that the evidence was insufficient to provide a reasonable basis for its performance claims such as Senior Moment will alleviate the “tip of the tongue” memory problems or that Senior Moment “enhances” memory function.
NAD previously recommended that “clinically proven” memory claims for Procera AVH supplements be discontinued or modified despite the advertiser possessing a peer-reviewed, double-blind, randomized, placebo-controlled clinical trial on the supplement product itself. NAD has also reviewed cognitive and memory enhancement claims for a variety of populations seeking to stave off mental decline or simply optimize cognitive performance.
The advertiser sells Cebria through its website and hosts a YouTube channel that includes video testimonials claiming that Cebria will improve memory. At the outset of NAD’s review, the advertiser argued that NAD should administratively close the matter because the Federal Trade Commission (FTC) had already reviewed the challenged claims and closed the investigation without taking any formal action.
NAD noted in its decision, however, that with “a large percentage of the population entering into its older years, exercising jurisdiction over dietary supplement claims that make the types of broad, establishment and quantified performance claims such as the advertiser makes here, especially warrants an expenditure of NAD resources.” NAD declined to administratively close the matter and turned to a review of the claims at issue, including:
- “Think Faster & Remember More with Cebria”
- “Improve Your Memory in just 30 Days”
- “Features a patented blend of neuropeptides that works to build new neuro-connections helping to restore short-term memory.”
- “Research results indicate that Cebria® creates a significant improvement in memory.”
- “Aids in protecting your memory.”
Both the YouTube Channel and the Advertiser’s website (www.cebria.com/testimonials.html) feature a number of testimonials, including:
- “I don’t stop in the middle of a sentence, trying to figure out what word I’m supposed to say next that means what I’m trying to say.*- Yvette Murphy, Age 46”
- “I thought I’m forgetting so many things. Don’t have that anymore. I don’t even think about that. I’m not even worried about that.*- Don Ward, Age 59”
The advertiser explained that Cebria contains the active ingredient, N-PEP-12. In its papers, the advertiser described N-PEP-12 as “a purified and standardized, patented neuro-peptide blend.” The advertiser maintained that N-PEP-12 was developed to support cognitive function in healthy individuals with normal age-related memory loss. The advertiser submitted six studies on the main active ingredient N-PEP-12, including three human clinical trials. The advertiser further submitted expert opinion reports.
The advertiser did not submit any clinical testing on the Cebria product as a whole, but rather submitted a study on one ingredient in Cebria, N-PEP-12.
As a general rule, NAD noted in its decision, product performance claims “should be supported by competent and reliable evidence, with the gold standard being testing on the product itself. It is well-established that when there is substantiation only for the efficacy of ingredients in a product, but not for the product itself, any claims must be clearly expressed as ingredient claims.”
NAD noted, however, that reliable and methodologically sound studies on the ingredients in a product may support properly qualified claims when the ingredients are present in the same amount, formulation and route of administration as studied.
NAD examined the advertiser’s studies to determine if they were sufficient to support properly qualified ingredient health claims and concluded that the study evidence was not a good fit for the advertiser’s strong, unqualified claims.
Cebria, in its advertiser’s statement, said the company will appeal NAD’s decision to the National Advertising Review board. “Cebria is particularly frustrated by NAD’s decision because Cebria was previously subjected to a rigorous expert review by the Federal Trade Commission, which then closed the investigation without taking any formal action against Cebria. By rejecting Cebria’s evidence, NAD seeks to set an evidentiary requirement for dietary supplement marketers that exceed those set by both the Food and Drug Administration and the Federal Trade Commission,” the company said.
Note: A recommendation by NAD to modify or discontinue a claim is not a finding of wrongdoing and an advertiser’s voluntary discontinuance or modification of claims should not be construed as an admission of impropriety. It is the policy of NAD not to endorse any company, product, or service. Decisions finding that advertising claims have been substantiated should not be construed as endorsements.