National Advertising Division Finds Certain Claims for Brainiac Applesauce and Gummy Vitamins Supported; Recommends Others be Discontinued or Modified
New York, NY – January 22, 2025 – As part of its routine monitoring program, BBB National Programs’ National Advertising Division determined that Ingenuity Brands, Inc., dba Ingenuity Brands and Brainiac Foods, provided a reasonable basis for certain claims in product packaging and online advertising for its Brainiac Brain Squeezers Applesauce products and BrainPack Daily Adult Gummy Vitamins. However, the National Advertising Division (NAD) recommended that other claims be discontinued or modified.
Applesauce Claims
NAD determined that Ingenuity provided a reasonable basis for the following Brainiac Brain Squeezers Applesauce claims:
- “Supports Immunity”
- “Brainiac snacks help close the brain nutrition gap”
- “Backed by Science, Loved by Families; Brainiac partnered with Parents, Pediatricians and Neurologists to create a line of delicious snack favorites packed with key nutrients that fuel the body AND brain. Learn more about brain nutrition at www.brainiacfoods.com”
NAD also concluded that the claim quantifying the extent of the nutrition gap that Ingenuity’s products are designed to help fill is supported based on WHO/FAO recommended intakes:
- “Most kids only get 20% of the recommended daily intake of Omega-3s, the most important building blocks of the brain*. That’s precisely why we formulated Brain Squeezers with our proprietary BrainPack®, a blend of DHA/EPA and choline to support the development of big, healthy brains. *Daily Adequate Intake Recommendations for Omega-3s and Choline: Based on World Health Organization/FAO UN and National Institutes of Health. Consumption data sourced from What We Eat in America, NHANES 2015- 2016.”
NAD found that in context, the “promotes brain health” claim conveyed a message that the applesauce provided important cognitive benefits beyond simply supporting brain health. Given the gap between the strength of the DHA in the applesauce and that tested in the underlying studies, NAD concluded that the cognitive benefits message was not supported and recommended that the “promotes brain health” claim be discontinued or modified to avoid overstating the benefits of the product.
NAD also recommended that Ingenuity discontinue the claim “clean ingredients” for its applesauce products and stated that to the extent Ingenuity wishes to make a “clean ingredients” claim in the future, it should ensure that the claim is properly supported and qualified to make clear the basis for the assertion that the product’s ingredients are “clean.”
BrainPack Daily Adult Gummy Vitamins Claims
NAD determined that one reasonable message conveyed by the label claims “Memory,” “Clarity,” “Focus,” and “Vision” was that the BrainPack Daily Adult Gummy Vitamins product would improve cognitive performance in a measurable way, a claim that was not supported by the record. Therefore, NAD recommended that the claims be discontinued or modified to avoid overstating the benefits of the vitamins.
During the proceeding, Ingenuity permanently discontinued certain claims for Brainiac Brain Bars and Brain Squeezers Applesauce. Therefore, NAD did not review these claims on their merits and will treat the claims, for compliance purposes, as though NAD recommended they be discontinued.
In its advertiser statement, Ingenuity stated that although it disagrees “with elements of the NAD’s analysis, it “agrees to comply with NAD’s recommendations.”
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