NAD Finds “Whole Home and Building Purification” Claims for RGF Air Purification Devices Supported; Recommends Certain Other Claims be Discontinued

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New York, NY – June 1, 2022 – The National Advertising Division (NAD) of BBB National Programs determined that RGF Environmental Group, Inc., manufacturer of RGF Air Purification Devices, can make certain general efficacy claims, including that the REME HALO air purifier “provides whole home and building purification.”

However, NAD recommended that the advertiser discontinue claims that:

• The REME HALO air purifier provides “total indoor air purification”;
• The REME HALO air purifier “kills up to 99% of bacteria, mold and viruses”;
• The REME HALO air purifier “reduces sneeze germs by 99% in the time a sneeze can reach three feet”; and
• The REME HALO is “designed to eliminate sick building syndrome risks by reducing odors, air pollutants, VOCs (chemical odors), smoke, mold, bacteria and viruses,” as well as the nearly identical claim for the GUARDIAN QR+ device.

NAD also recommended that the advertiser discontinue certain claims relating to the safety of the emissions generated by the RGF devices.

The claims at issue were challenged by Synexis LLC, a manufacturer of competing air purification devices. Synexis challenged advertising by RGF for its REME HALO, REME MARINER, REME ATS, and Guardian QR+ air purification devices, which are intended to optimize the Indoor Air Quality (IAQ) within building environments, including homes and public spaces. IAQ is determined by the levels of toxic gases, particulates, microbial contaminants (such as mold, bacteria, and viruses), and other pollutants that can exist in the air and on surfaces. 

“Total Indoor Purification” Claims

Regarding the advertiser’s claim that the REME HALO air purifier provides “total indoor air purification,” NAD determined that consumers may reasonably take away the message that the device provides and maintains a continuous, complete, and 100% pollutant-free environment. While the advertiser submitted evidence as to the general efficacy of its devices, NAD noted that the advertiser did not submit evidence to support a “total indoor purification” message.

Accordingly, NAD recommended that RGF discontinue the claim that the REME HALO offers “Total Indoor Air Purification,” as well as the related implied claims that RGF’s test results are reflective of real-world results that would support a claim of “total” purification or that RGF’s technology can purify the totality of a home or building space by ridding indoor air of 100% of contaminants.

“Whole Home” Claims

In contrast to a standalone air purifier placed in a particular room, both the REME HALO and the Guardian QR+ are typically installed in the ducting or through HVAC systems and are characterized as “whole home” air purifiers.

NAD determined that the claims that “REME HALO® provides whole home and building purification” and “Whole Home Air Purification System…Kills Bacteria and Viruses on Surfaces and In The Air…Patented Technology, Third-Party Tested, Validated and Proven” reasonably convey the message that the devices are generally effective. 

NAD also concluded that the claim that the GUARDIAN QR+ line is “proactive and sends ionized aggressive advanced oxidizers into the room to destroy the pollutants at the source, in the air and on surfaces” reasonably conveys a message about the devices’ advertised mechanism of action.

After examining the evidence, NAD concluded that these general efficacy claims were supported. NAD noted that RGF provided extensive testing and analyses of its products, conducted by many well-credentialed third-party laboratories and academic researchers, which yielded consistent results over many years demonstrating an improvement in indoor air quality. Further, NAD found that a significant number of the studies submitted were performed in consumer-relevant or real-world conditions.

Accordingly, NAD determined that RGF has a reasonable basis for such claims, as well as the related implied claim that RGF’s test results are reflective of real-world results. 

“99%” and Sneeze Germ Claims

Regarding the claim that the REME HALO “Kills up to 99% of bacteria, mold and viruses,” NAD noted that the claim appears in a standalone context where a reasonable takeaway is that the device kills up to 99% of all bacteria, mold, and viruses in a given space. Another reasonable takeaway is that the “99%” is a reference to the range of types of “bacteria, mold and viruses” that the REME HALO can eliminate. 

After reviewing the advertiser’s evidence NAD determined that neither message was adequately supported and recommended that the claim be discontinued. 

NAD noted that nothing in its decision precludes the advertiser from making truthful and non-misleading claims about the range of bacteria, mold, and viruses its devices are capable of killing or the quantity of bacteria, mold, and viruses able to be killed in a given space.

NAD also recommended that the advertiser discontinue claims that:

• The REME HALO “Reduces sneeze germs by 99% in the time a sneeze can reach three feet,” and
• The Guardian QR+ “Kills 99% of Sneeze Germs Within 3 Feet.” 

NAD found that the advertiser’s supporting evidence was flawed and, further, that some of the advertising conveys a message through imagery that the RGF devices would “instantly” kill sneeze germs during the sneeze, a message that did not fit with testing that measured the effect at longer time intervals.

Health Benefit Claims

NAD determined that the message reasonably conveyed in the challenged advertising is that the RGF devices are more than simply “designed to eliminate” the risks associated with Sick Building Syndrome, but that they eliminate or neutralize those risks. NAD found that the evidence did not support that message. 

Therefore, NAD recommended that the advertiser discontinue:

• The claim that REME HALO is “designed to eliminate Sick Building Syndrome risks by reducing odors, air pollutants, VOCs (chemical odors), smoke, mold, bacteria, and viruses”;
• The claim that GUARDIAN QR+ device is “designed to eliminate sick building syndrome risks by neutralizing odors, air pollutants, VOCs (chemical odors), smoke, mold, bacteria and viruses”; and
• The implied claim that RGF has conducted studies that establish that its devices eliminate the risks associated with sick building syndrome and work throughout a whole home.

NAD noted that nothing in its decision precludes the advertiser from making truthful and non-misleading claims about the devices’ efficacy with respect to any of the individual risk factors associated with Sick Building Syndrome.

Safety Claims

Regarding the advertiser’s claim that the GUARDIAN QR+ unit creates “an Advanced Oxidation Plasma consisting of Ionized Hydro-peroxides, Super oxide ions, and Hydroxide ions. All are friendly oxidizers,” NAD determined that consumers may reasonably infer that RGF’s technology does not produce any undesirable or “unfriendly” substances such as ozone. Because it was not demonstrated that the RGF devices were “ozone-free,” NAD recommended that the advertiser discontinue the claim that its devices create “friendly oxidizers.”

NAD also recommended that the advertiser discontinue the claim that “There is no known case of hydroperoxides ever creating a health risk.” NAD noted that while it may be an accurate statement and nothing in the record indicated that hydroperoxides do create health risks, the level of certainty with which this claim is expressed conveys an unsupported message that hydroperoxides have been exhaustively studied to the point of ruling out any single adverse health effect.  

NAD noted that nothing in its decision precludes the advertiser from making truthful and non-misleading claims regarding the proven safety of its devices and the emissions they generate.

Finally, during the proceeding, the advertiser permanently discontinued several challenged express and implied claims. Therefore, NAD did not review these claims on the merits.

In its advertiser statement, RGF stated that it “will comply with NAD’s recommendations.” Further, while the advertiser expressed disappointment with NAD’s conclusion regarding the message conveyed by its “friendly oxidizers” claim it stated that it will “take the NAD’s recommendations into account in future advertising and agrees to comply with the NAD’s recommendations with respect to any of its advertising still in use at present. 

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