National Advertising Division Will Refer Willow Health to State and Federal Regulatory Authorities for its Compounded Semaglutide Product Claims
New York, NY – December 4, 2025 – Following a challenge brought by Novo Nordisk Inc., BBB National Programs’ National Advertising Division recommended Willow Health Services, Inc. modify or discontinue health-related claims for its compounded semaglutide products.
Willow Health is a telehealth company that markets compounded drugs to patients and physicians nationally. Willow Health’s compounded semaglutide product line includes two products: “Semaglutide Tablets” and “Semaglutide Plus,” a compounded semaglutide product for injection.
Challenger Novo Nordisk is a global pharmaceutical company specializing in obesity, diabetes care as well as other chronic conditions including rare diseases and cardiovascular conditions. Novo Nordisk markets the only FDA-approved semaglutide medicines, including Ozempic®, Wegovy®, and Rybelsus®. Novo Nordisk challenged Willow Health's express and implied claims regarding its compounded semaglutide product’s claimed superiority, safety, efficacy, and health benefits.
As support for the challenged claims, Willow Health asserted that prescribing decisions made by the individual doctors who consult with each Willow customer are sufficient to substantiate its advertising. Additionally, Willow Health relied on its own statements made in disclosures that its semaglutide products have not been subjected to clinical trials assessing safety or effectiveness.
The National Advertising Division (NAD) determined that Willow Health did not provide evidence to substantiate its express claims regarding health, weight loss, implied benefits, superiority, or the establishment of efficacy. The only sources referenced by Willow Health are published studies concerning Novo Nordisk’s FDA-approved semaglutide products, which NAD found are insufficient to validate claims for compounded alternatives that differ in active pharmaceutical ingredient, formulation, and method of administration.
NAD therefore determined that Willow Health did not establish a reasonable basis for the challenged express and implied claims and recommended it discontinue or modify its advertising to avoid conveying the challenged express and implied claims.
Willow did not provide an advertiser’s statement confirming that it will comply with the NAD recommendations, indicating instead that “Willow maintains that the challenged advertising is truthful and can be substantiated, and therefore does not at this time agree to comply with NAD’s recommendations.”
Because Willow did not provide an advertiser statement confirming that it will comply with the NAD recommendations, NAD will refer Willow Health to the appropriate regulatory authorities, including the relevant state Attorneys General pursuant to Section 5.1(A) of the NAD/NARB Procedures as well as platforms on which the advertising appeared and with which NAD has a reporting relationship.
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. Per NAD/NARB Procedures, this release may not be used for promotional purposes.
Willow Health is a telehealth company that markets compounded drugs to patients and physicians nationally. Willow Health’s compounded semaglutide product line includes two products: “Semaglutide Tablets” and “Semaglutide Plus,” a compounded semaglutide product for injection.
Challenger Novo Nordisk is a global pharmaceutical company specializing in obesity, diabetes care as well as other chronic conditions including rare diseases and cardiovascular conditions. Novo Nordisk markets the only FDA-approved semaglutide medicines, including Ozempic®, Wegovy®, and Rybelsus®. Novo Nordisk challenged Willow Health's express and implied claims regarding its compounded semaglutide product’s claimed superiority, safety, efficacy, and health benefits.
As support for the challenged claims, Willow Health asserted that prescribing decisions made by the individual doctors who consult with each Willow customer are sufficient to substantiate its advertising. Additionally, Willow Health relied on its own statements made in disclosures that its semaglutide products have not been subjected to clinical trials assessing safety or effectiveness.
The National Advertising Division (NAD) determined that Willow Health did not provide evidence to substantiate its express claims regarding health, weight loss, implied benefits, superiority, or the establishment of efficacy. The only sources referenced by Willow Health are published studies concerning Novo Nordisk’s FDA-approved semaglutide products, which NAD found are insufficient to validate claims for compounded alternatives that differ in active pharmaceutical ingredient, formulation, and method of administration.
NAD therefore determined that Willow Health did not establish a reasonable basis for the challenged express and implied claims and recommended it discontinue or modify its advertising to avoid conveying the challenged express and implied claims.
Willow did not provide an advertiser’s statement confirming that it will comply with the NAD recommendations, indicating instead that “Willow maintains that the challenged advertising is truthful and can be substantiated, and therefore does not at this time agree to comply with NAD’s recommendations.”
Because Willow did not provide an advertiser statement confirming that it will comply with the NAD recommendations, NAD will refer Willow Health to the appropriate regulatory authorities, including the relevant state Attorneys General pursuant to Section 5.1(A) of the NAD/NARB Procedures as well as platforms on which the advertising appeared and with which NAD has a reporting relationship.
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. Per NAD/NARB Procedures, this release may not be used for promotional purposes.