BBB National Programs Archive

NAD Recommends Cerebral Success Discontinue Certain Claims for SmartX Dietary Supplement

New York, NY – Sept. 23, 2014 – The National Advertising Division has recommended that Cerebral Success, maker of the dietary supplement “SmartX,” discontinue a wide range of claims challenged by the Council for Responsible Nutrition (CRN).

NAD is an investigative unit of the advertising industry’s system of self-regulation and administered by the Council of Better Business Bureaus. As part of an initiative with CRN to expand the review of advertising claims for dietary supplements, NAD examined the advertiser’s evidence for its product-performance claims, ingredient claims and consumer testimonials.

SmartX is made with ingredients that include Cognizin, Caffeine and L-Theanine, Huperzine A, DHA, and L-Tyrosine.  NAD noted in its decision that there may be “some limited circumstances under which health performance claims can be substantiated without clinical studies” on the actual product.

In such cases, NAD noted, “an advertiser must demonstrate by reliable evidence that it is scientifically sound to extrapolate the conclusions drawn … and apply them to the performance of the product in question.”

In this case, NAD noted the data submitted by the advertiser did not support such extrapolation; studies provided by the advertiser did not test SmartX products or formulas similar to SmartX’s combination of ingredients and were limited to various findings on individual SmartX ingredients.

Following its review, NAD recommended that the advertiser discontinue product performance claims for SmartX, including:

  • “Designed to enhance memory, focus & mental agility: boost focus & concentration; stimulate mental energy & agility; enhance memory & recall; improve brain health & function; and reduce anxiety”
  • “Is Cerebral Success an Adderall Alternative? . . . Cerebral Success was specifically designed as a study pill to provide an Adderall alternative for students who are taking the drug without a prescription.  It is not, however, designed to treat the condition.  Along with focus and mental energy (the hallmarks of Adderall), Cerebral Success was designed to increase memory and strengthen and protect the brain, which Adderall does not do.”

NAD determined that the advertiser provided a reasonable basis for certain claims regarding the benefits of Cognizin, Caffeine and L-Theanine, Huperzine A, DHA, and L-Tyrosine.  However, in the absence of competent and reliable scientific evidence, NAD recommended that the advertiser discontinue claims that:

  • L-Theanine “works to balance out the harsher effects of caffeine”
  • Huperzine A “has been proven useful in improving short term memory as well as preventing long term memory loss as a result of aging”
  • L-Tyrosine supports “an increased feeling of well-being” and “has an antioxidant effect, which helps protect cell membranes from damage caused by free radicals.”

NAD further recommended that the advertiser discontinue ingredient claims regarding Bacopin, Vinpocetine, Phosphatidylserine, Glucuronolactone, Schisandrin A,  L-Glutamine, and B-Vitamins.

NAD determined that that the advertiser provided a reasonable basis for the claims:

  • “We pack in a bunch of ingredients that are clinically shown to increase focus & improve memory.”
  • Ingredients contained in SmartX are intended to “provide needed vitamins, nutrients & amino acids.”

However, NAD recommended that the advertiser discontinue its unsupported claims that the ingredients contained within SmartX “are intended to strengthen brain cell walls,” “increase blood flow & oxygenation to the brain; stimulate protein synthesis; and boost production of acetylcholine.” 

NAD further recommended that the advertiser discontinue the use of consumer testimonials that contain unsupported product performance claims.

Cerebral Success, in its advertiser’s statement, said that while the company disagreed with “some aspects of the decision,” the company “respects and supports the self-regulatory process, and it will consider NAD’s recommendations in all future advertising, as well as alter our current advertising based on the recommendations provided.”