National Advertising Division Recommends Noom Modify or Discontinue “A Smaller Dose. A Smarter Start” Claim for Microdose GLP-1RX Program
New York, NY – May 26, 2026 – In a challenge brought by Eli Lilly and Company, BBB National Programs’ National Advertising Division recommended that Noom, Inc. modify or discontinue its Microdose GLP-1RX Program “A Smaller Dose. A SmarterStart” claim.
Lilly and Noom compete in the weight-loss market. Lilly markets tirzepatide-based prescription medications Mounjaro® and Zepbound®. Noom is a weight-loss platform that offers GLP-1 medications in conjunction with its behavior-change program.
At issue for the National Advertising Division (NAD) was whether the claim “Noom GLP-1Rx Program A Smaller Dose. A Smarter Start. Microdose GLP-1Rx Starts at $119*.” constituted non-actionable puffery or, in context, conveyed an objective health-related message requiring substantiation.
NAD determined that one message reasonably conveyed by the challenged claim is that Noom’s product is “smarter” due to its “smaller” dose, and that the smaller dosage provides a measurable, health-related benefit, which requires substantiation.
NAD found that Noom did not provide adequate support for the message that Noom’s specific lower-dose approach provides a measurable health-related benefit that makes it a “smarter start.”
Accordingly, NAD recommended that Noom discontinue the claim “NOOM GLP-1Rx PROGRAM A Smaller Dose. A Smarter Start. MICRODOSE GLP-1Rx STARTS AT $119*” or modify its advertising to avoid conveying the message that the lower dose of medication provided by the Noom Microdose GLP-1Rx Program itself provides a measurable, health-related benefit that makes it a smarter or better way to begin treatment.
NAD noted that nothing in its decision precludes Noom from promoting its program or the benefits of its behavior-modification tools as a smarter start, provided the advertising does not tie that message to unsupported dosage-related benefits.
During the inquiry, Noom informed NAD that it was permanently discontinuing all other challenged express claims, including dosing, efficacy, side effect, and other health-related claims. Based on Noom’s representation that the discontinued claims were being permanently discontinued, NAD did not review them on their merits and will treat the permanently discontinued claims, for compliance purposes, as though NAD recommended they be discontinued.
In its advertiser statement, Noom stated that while it “disagrees with NAD’s conclusion,” it “voluntarily agrees to comply with NAD’s recommendation.”
All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Pursuant to NAD/NARB Procedures, this release may not be used for promotional purposes.
Lilly and Noom compete in the weight-loss market. Lilly markets tirzepatide-based prescription medications Mounjaro® and Zepbound®. Noom is a weight-loss platform that offers GLP-1 medications in conjunction with its behavior-change program.
At issue for the National Advertising Division (NAD) was whether the claim “Noom GLP-1Rx Program A Smaller Dose. A Smarter Start. Microdose GLP-1Rx Starts at $119*.” constituted non-actionable puffery or, in context, conveyed an objective health-related message requiring substantiation.
NAD determined that one message reasonably conveyed by the challenged claim is that Noom’s product is “smarter” due to its “smaller” dose, and that the smaller dosage provides a measurable, health-related benefit, which requires substantiation.
NAD found that Noom did not provide adequate support for the message that Noom’s specific lower-dose approach provides a measurable health-related benefit that makes it a “smarter start.”
Accordingly, NAD recommended that Noom discontinue the claim “NOOM GLP-1Rx PROGRAM A Smaller Dose. A Smarter Start. MICRODOSE GLP-1Rx STARTS AT $119*” or modify its advertising to avoid conveying the message that the lower dose of medication provided by the Noom Microdose GLP-1Rx Program itself provides a measurable, health-related benefit that makes it a smarter or better way to begin treatment.
NAD noted that nothing in its decision precludes Noom from promoting its program or the benefits of its behavior-modification tools as a smarter start, provided the advertising does not tie that message to unsupported dosage-related benefits.
During the inquiry, Noom informed NAD that it was permanently discontinuing all other challenged express claims, including dosing, efficacy, side effect, and other health-related claims. Based on Noom’s representation that the discontinued claims were being permanently discontinued, NAD did not review them on their merits and will treat the permanently discontinued claims, for compliance purposes, as though NAD recommended they be discontinued.
In its advertiser statement, Noom stated that while it “disagrees with NAD’s conclusion,” it “voluntarily agrees to comply with NAD’s recommendation.”
All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Pursuant to NAD/NARB Procedures, this release may not be used for promotional purposes.