New York, NY – July 17, 2019 – Following a challenge by Johnson & Johnson Consumer Inc., the National Advertising Division recommended that Wink Naturals LLC discontinue certain challenged anxiety relief, natural, and drug-free claims in product packaging, website, social media, and third-party advertising for its Zen Drops.

NAD is an investigative unit of the advertising industry’s system of self-regulation and is a division of the BBBNP’s self-regulatory and dispute resolution programs.

The claims challenged by J&J included, but were not limited to:

• Anxiety relief claims, such as “Passion flower extract is the powerful, natural ingredient in our Zen Drops formula that’s clinically proven to provide natural, drug-free relief from feelings of anxiousness.”
• Natural, drug-free claims, such as “Our proprietary formula is 100% natural, drug-free and non-habit forming and was designed to provide relief without any of the negative side effects.”
• Implied claim that Zen Drops can treat anxiety disorders in adults and children as well as, or better than, prescription medications and as a safer alternative without any side effects.
• Hashtag claim “#mentalhealthawareness.”

Zen Drops is a dietary supplement containing 2000 mg of passion flower extract per serving size of two full droppers.  The product also contains glycerin, water, and natural flavoring.  NAD noted that the challenged website, social media, and testimonial claims, many of which have since been discontinued, focus on anxiety relief and several claims are directed towards children.

The advertiser informed NAD in writing that it permanently discontinued certain claims, including:

• “All-Natural ingredients which have been clinically proven and tested.”
• “Drug-free relief from feelings of anxiousness.”
• “Natural stress-relief.”
• “Safe for children  . . . ages 3 and older.”
• “I get asked A LOT if we make an anxiety product for kids – WE DO.”
• “[W]ithout any of the side effects commonly associated with chemically based interventions and prescription medication.”
• “Promotes calming relief for anxiety without drugs.”

The discontinued claims also include social media and website testimonials that tout Zen Drops’ effectiveness in treating postpartum depression and anxiety in adults, as well as anxiety disorders in children; and claims that the drops improve concentration and focus for children in school.  In addition, the advertiser permanently discontinued its use of the hashtags “#anxietyhelp,” “#mentalillnessisreal,” and “#anxiousness.” NAD, relying on the advertiser’s representations that the claims have been permanently discontinued, did not review the claims on their merits.  However, the voluntarily discontinued claims will be treated, for compliance purposes, as though NAD recommended their discontinuance and the advertiser agreed to comply.

NAD considered the remaining challenged express and implied anxiety relief claims and recommended that the advertiser discontinue the claims, “Passion flower extract has been clinically proven to help aid in anxiety relief”; “Clinically proven ingredients”; and “Passion flower extract is the powerful, natural ingredient in our Zen Drops formula that’s clinically proven to provide natural, drug-free relief from feelings of anxiousness.”  NAD determined that the studies referenced by Wink were not a good fit to support its claims for several reasons, including that the dosage of Zen Drops was not studied in any of the three studies submitted by the advertiser, and that the formulation of Zen Drops did not match those of the underlying ingredient studies.  NAD also recommended discontinuance of the advertiser’s modified claim that “Passion flower extract is the powerful, natural ingredient in our Zen Drops formula that’s clinically proven to provide natural, drug-free relief from feelings of uneasiness and stress.”  While NAD appreciated that the advertiser stated that it would remove references to the term “anxiety,” it cautioned the advertiser to avoid making any unsupported express or implied claims about the relief provided by passion flower extract.

Further, because none of the advertiser’s studies focused on the side effects or non-habit forming nature of Zen Drops (or the side effects of ingredients in the amount and formulation of Zen Drops), NAD recommended that the advertiser discontinue claims regarding Zen Drops’ side effects and non-habit forming nature.  NAD found, however, that with the removal of language regarding relief and anxiousness, the advertiser could make a limited claim that its product is “drug-free.”

NAD determined that one message reasonably conveyed by using the hashtag “#mentalhealthawareness” in conjunction with an image of a woman holding a bottle of Zen Drops is that the product has a connection to mental health.  Wink did not provide adequate support for its claims that Zen Drops relieves anxiety, or any other type of mental illness.  Therefore, NAD recommended that the advertiser discontinue use of this hashtag in conjunction with images of Zen Drops or other claims regarding Zen Drops.

Finally, NAD declined to recommend that the advertiser discontinue the product label dosing instructions directed towards children, but cautioned the advertiser to avoid making unsupported express or implied claims directed toward children and noted that it may exercise its discretion to open a monitoring inquiry in the future.

In its advertiser’s statement, Wink Naturals stated that it “intends to comply with the recommendations of NAD” and that it “has already voluntarily modified its advertising.”