Case #238-2025: Government Referral – Acti-Labs Ltd. d/b/a Urban Retreat by Acti-Labs

BBB NATIONAL PROGRAMS

Direct Selling Self-Regulatory Council
Case #238-2025: Government Referral – Acti-Labs Ltd. d/b/a Urban Retreat by Acti-Labs


 

Company Description

Acti-Labs Ltd., doing business as Urban Retreat by Acti-Labs (“Urban Retreat” or the “Company”), is a consumer products company originally established in 2011 as a direct-selling marketer. In 2021, the Company adopted the trade name Urban Retreat by Acti-Labs. Urban Retreat markets a range of products including skincare, body care, wellness, cosmetics, and haircare. According to publicly available records, the business is registered in Rockford, Illinois.1



Basis of Inquiry

The Direct Selling Self-Regulatory Council (“DSSRC”), a national advertising self-regulation initiative administered by BBB National Programs, commenced this inquiry pursuant to its ongoing independent monitoring of advertising and marketing claims within the direct selling channel.

This inquiry involved a review of eight income-related representations and three product performance statements that were publicly disseminated on Facebook and Instagram. DSSRC expressed concern that the earnings-related content conveyed the message that prospective members of the Company’s salesforce could achieve substantial income from the Urban Retreat business opportunity — with references to terms such as “incredible income” and “financial freedom.” Additionally, DSSRC observed product-related statements that it concluded could reasonably be interpreted as implying that Urban Retreat’s products are capable of treating or alleviating serious health-related conditions.

The representative claims identified by DSSRC in this inquiry were as follows:

  1. Earnings Claims
    1. “Well fast forward to today and this business has changed my life! It’s enabled me to watch my boys grow up and be there for them every day. I’ve had beautiful cars, luxury holidays, spa days, jewellery, crazy bonuses and have built an incredible income all whilst working at home! Annndddddd the best bit is yet to come...... in just 3 weeks we’re about to change this industry and do something that’s NEVER been seen before and I couldn’t be more proud to be at the forefront of it all!” (May 2021)
    2. “And have now found my home at Urban Retreat by Acti Labs. I absolutely love and have a passion for Natural Health and Wellness and enjoy helping others with their goals and Financial Freedom too.” (February 2023)
    3. “𝐖𝐡𝐚𝐭 𝐰𝐨𝐮𝐥𝐝 𝐚𝐧 𝐞𝐱𝐭𝐫𝐚 £𝟕𝟎 𝐚 𝐰𝐞𝐞𝐤 𝐦𝐞𝐚𝐧 𝐟𝐨𝐫 𝐲𝐨𝐮 ? Most people don’t partner with me for financial freedom. They partner with me for financial breathing space and Don’t discredit being able to earn an extra 100-500 a month! This to some, is what takes that huge financial burden off their shoulders! (April 2024)
    4. “So many people think NWM is a scam, it doesn't pay good money - This was my sales November last year. I hit over 700 in sales before the end of November. Given me even MORE COMMISSION. £116 in weekly commissions. Total commission of £218 before anymore sales went through. Then my monthly commission was £145 I had received on 7th of December. Now looking at this would you say it doesn't pay? What would £218 do for you? The more work you put in the better. I paid £55 to join urban retreat AKA ACTI-LABS. I've had that back & so much more.” (January 2024)
    5. “I had no money left over after bills, I went to bed worrying about money and woke up worrying, I had no confidence, I was doubting myself, I was depressed (I tried taking my own life 3 times), and I wasn't living I was just existing. And as for what I have gained? Well... I've gained financial freedom. I've gained clinically proven products that I love and believe in. (May 2021)
    6. “This business isn't just about having financial freedom. It's about building relationships, making friends, helping others and helping yourself to be the person you're truly meant to be!!” (April 2021)
    7. “I was able to leave my job and build my business full time from home. I have had 3 brand new company cars and upgrades, I have been able to move into a new home which I love AND have now began my journey of property development and investment.”
    8. “I have a stable and secure income and earn more monthly than I was ever able to, even while working full time in a professional career AND running my own restaurant. And I get to work from home, choose my own schedule, travel, visit family and friends and really ENJOY my free time…. More Time Freedom. More Financial Freedom. FREEDOM...... from whatever is stopping you being the happiest, best version of yourself!” (December 2023)
    9. “Having multiple streams of income is so important now a days! I definitely have landed something BIG! I have partnered with 6/7/8 figure $ earners and I'm so excited for this new adventure!” (February 2023)

     

Product Performance Claims:

  1. “Our amazing Balance Capsules that are 100% natural, not only help to balance out your hormones naturally but they also help with:
    Energy
    Weight-loss
    Skin problems (acne, eczema, rosacea)
    Stress/ Anxiety / depression
    Aches & Pains
    Mood swings
    Sleep
    PMS
    Peri/Menopause
    Digestion
    Endometriosis
    And much more ” (February 2023)
  2. “Why suffer with Menopausal Symptoms, even whilst on HRT when these can help for less than 65p a day!! … #menopause #perimenopausehealth #womenshealth #menopausesymptoms #menopausesucks #hotflashes #menofog #brainfog #pmtslife #hormones #hrt #moodswings #nightsweats #weightgain #jointpain #palpatations #insomnia #thinninghairsolution #dryskin #lossoflibido #brittlenails #depression #anxiety #irregularperiods”(October 2023)
  3. “Going into this part of my Urban Retreat journey, weight loss and inch loss, I did not know how I would be able to share my results. Fear… Embarrassment… Vulnerability… putting yourself out there can be really hard. But, YALL…. I’m posting these results… MY results because I am SOO EXCITED and SOOO PROUD! Two weeks on this Sip n Slim Bundle, One week of Lipo Sculpting Fluid… 8 pounds GONE!! 8 inches GONE!! FIRMER! WHAT CELLULITE??? I cannot WAIT to see what the next two weeks bring!! CLINICALLY PROVEN RESULTS!” (February 2023) 



Company Position

Earnings Claims & Jurisdictional Objection

Urban Retreat did not submit substantiating data for the earnings claims identified in this inquiry. In its response to DSSRC’s Notice of Inquiry, the Company reported that it experienced a major operational setback in March 2023 when a fire—originating from an adjacent property—destroyed its distribution facility in Andover, England.

Urban Retreat explained that it formally discontinued its multi-level marketing operations by the end of 2024 and now operates exclusively as an e-commerce business supported by a small-scale affiliate program. It also noted that its current affiliates promote a variety of brands and do not engage in income-related representations in their promotional efforts.

Accordingly, Urban Retreat asserted that because its current business model no longer includes multi-level marketing activities, the matter fell outside the scope of DSSRC’s jurisdiction.

With respect to the claims at issue, Urban Retreat stated that the social media content cited by DSSRC was posted by individuals who have not been associated with the Company since 2023 and with whom it no longer has any ongoing relationship.



Product Performance Claims

The Company did not provide evidence to support the health-related claims made in the first two product performance posts.

As substantiation for its claim that using the Urban Retreat Detox & Slim Bundle leads to users losing 8 pounds and 8 inches in two weeks, and that these results were “clinically proven,” the Company directed DSSRC to two studies available on the Urban Retreat website.

  • The Evaluation of the Slimming Efficacy of a Food Supplement - Controlled Study Versus a Placebo

This 2019 study evaluated the slimming efficacy of Hydra-Slim in terms of reduction of body weight and body circumference. 40 subjects participated in the study and were randomly divided into a treatment group and a placebo group (i.e., 20 subjects in each group). The effectiveness of the product was assessed after 15 and 30 days by measuring waist, hip, and thigh circumferences, as well as evaluating body weight.

The Company maintained that the study results showed that 90% of Hydra-Slim Plus users lost weight, and an average waist-reduction of nearly –1 cm in one month, compared to no measurable change in the placebo group.

  • Assessment of the Immediate Elasticizing Effect of a Cosmetic Product

This clinical trial conducted by Acti Labs in France evaluated Lipo Sculpting Fluid’s instant benefits. A group of 20 volunteers applied the slimming cream to targeted areas (e.g. the inner thigh) and researchers measured skin elasticity shortly after application. The study examined how quickly skin “springs back” after being stretched – a key marker of firmness and elasticity related to skin aging. Skin elasticity was evaluated approximately 15 minutes after applying the product, using instruments to gauge the skin’s elastic recovery (its ability to return to original shape). The study also tracked visible cosmetic changes (inch loss and firming) on problem areas like the thighs, stomach, and buttocks, to see if a single 45-minute treatment session could tighten and tone the skin.

The Company stated that, according to the study results, Lipo Sculpting Fluid showed a notable immediate effect. Just 15 minutes post-application, participants’ skin elasticity had improved by roughly 6.8%, indicating the skin was noticeably more taut and elastic. This immediate “elasticizing” effect translated into perceivable tightening of the skin. Moreover, the trial reported measurable slimming and firming outcomes in the treated areas.

According to Urban Retreat, nearly all participants saw a reduction in  thigh circumference, even after one use. They also observed that their skin felt firmer and their silhouettes looked more toned – for example, thighs and bottoms appeared firmer, and many noted a flatter-looking stomach.

Urban Retreat asserted that the two studies in question offered sufficient substantiation for the weight-loss claims referenced in the social media post.



Analysis

 Jurisdiction

Although Urban Retreat asserted that DSSRC lacked jurisdiction in this matter because the Company no longer operates as a multi-level marketing organization and now follows an affiliate advertising model, DSSRC disagreed.

Section III of the DSSRC Policies & Procedures (“DSSRC Procedures”), expressly provides that “DSSRC reviews earnings claims and product claims made by any direct selling company and/or its salesforce members and evaluates the truthfulness, accuracy, and substantiation of such earnings claims and product claims.” As recognized by the Federal Trade Commission (FTC), “direct selling” encompasses a broad range of business structures built on person-to-person sales outside traditional retail settings, such as in homes or on social media platforms, with multi-level marketing constituting only one form of direct selling.2

Moreover, there is no dispute that at the time the challenged claims were disseminated, Urban Retreat was engaged in multi-level marketing.

As such, DSSRC concluded that for the purposes of this inquiry Urban Retreat is engaged in direct sales and this inquiry properly falls within DSSRC’s jurisdiction.



Earnings Claims

DSSRC determined that the earnings claims identified in this inquiry could reasonably be interpreted by consumers as suggesting that participants in the Company’s business opportunity were likely to achieve substantial income. More specifically, social media posts referencing prospective earnings—including claims of “financial freedom,” luxury automobiles, costly vacations, bonuses, and “incredible income”—were deemed to be inflated representations that do not reflect the likely experience of a typical Urban Retreat salesforce participant.

The FTC’s 2024 Business Guidance for Multi-Level Marketing states that any earnings representation must reflect the results typical consumers are likely to achieve and that companies must possess a reasonable basis for such claims at the time they are made.3 The Guidance further cautions that promoting atypical testimonials, such as those involving large or career-level income, can create a misleading impression of earning potential. Similarly, DSSRC’s Earnings Claims Guidance prohibits phrases such as “quit your job,” “replacement income,” or “financial freedom” when used in general marketing to prospective or current salesforce members, as these terms are likely to be deceptive.4

In the absence of data supporting the earnings representations communicated by Urban Retreat salesforce members, DSSRC recommended that the Company make a good faith effort to have the posts removed from social media.



Product Performance Claims

With respect to claims suggesting Urban Retreat products were effective in addressing various health-related conditions, including depression, PMS, perimenopause, and polycystic ovary syndrome, as well as promoting substantial weight loss, DSSRC determined that it was incumbent on the Company to assure that such claims were supported by reliable data consistent with the expectations of regulators and consumers.

With respect to health and safety claims, the FTC’s substantiation standard is a rigorous one, particularly when claims relate to health. FTC’s Health Products Compliance Guidance requires that efficacy claims for health-related products be supported by competent and reliable scientific evidence, defined as objective, expert-conducted studies that are sufficient in quality and quantity to substantiate the claims.5

Urban Retreat did not provide DSSRC with data to support the product performance claims communicated in the social media posts and, instead, pointed DSSRC to clinical testing results provided on the Urban Retreat website.

Accordingly, DSSRC reviewed the Urban Retreat website (https://www.urban-retreat.com/) for evidence of product efficacy with respect to the products referenced in the three social media posts identified in the inquiry.

  • Urban Retreat Balance Capsules & Urban Retreat UR Daily Balance

The first two social media posts identified in the Product Performance section of the Basis of Inquiry relate to the Company’s Balance Capsules and UR Daily Balance products. Both the posts and the corresponding product webpages included claims that the products could regulate hormones and alleviate various symptoms associated with menopause. While the product pages provide usage directions, ingredient lists, and supplement facts, DSSRC found no clinical studies on the Urban Retreat website to substantiate these claims—despite one salesforce member’s assertion in a post that Balance Capsules had been “tested in clinical trials.”

Based on these findings, DSSRC recommended that Urban Retreat make a good-faith effort to have both posts removed.

  • Detox Sip & Slim (Bundle) and UR Lipo Sculpting Fluid

The third social media post listed in the Product Performance section of the Basis of Inquiry features images of Urban Retreat’s Detox & Slim Bundle6 and the UR Lipo Sculpting Fluid accompanied by express weight loss claims (e.g., “8 pounds GONE” “8 inches GONE”) within a stated time period (“Two weeks on this Sip n’ Slim Bundle, One week of Lipo Sculpting Fluid…”). The post also asserts that these results are “CLINICALLY PROVEN.”

After reviewing the two studies cited by Urban Retreat in support of its weight-loss claims, DSSRC concluded that the referenced testing did not sufficiently substantiate claims regarding the combined use of the Detox & Slim Bundle and the UR Lipo Sculpting Fluid.

More specifically, the studies on Hydro-Slim and UR Lipo Sculpting Fluid were conducted by the Company itself rather than an independent third-party laboratory. The studies involved small sample sizes, lacked confirmation that either the administrators or the subjects were blinded, and did not assess either product over an eight-week period—the timeframe referenced in the claim. In addition, no testing was provided for the Ketocap dietary supplements, which appeared in the social media post as part of the Detox & Slim Bundle. As a result, there was no evaluation of how the products functioned when used together. DSSRC emphasizes that when an advertiser represents that a product bundle is “clinically proven,” it must provide testing on the full combination of products to demonstrate that the entire bundle produces the claimed results. This is particularly important because products used together may interact in ways that alter performance: some ingredients may reinforce one another, while others may diminish effectiveness or even lead to unintended side effects.

As such, DSSRC determined that the testing was insufficient to support the salesforce member’s claim of “8 pounds GONE … 8 inches GONE” as a result of “Two weeks on this Sip n’ Slim Bundle, One week of Lipo Sculpting Fluid…” or that the results were “CLINICALLY PROVEN.”

In its Health Products Compliance Guidance, the FTC states:

“When applied to claims about the efficacy or safety of health-related products, the factors described above make up the FTC’s rigorous substantiation standard of “competent and reliable scientific evidence.” The FTC has more specifically defined that standard as “tests, analyses, research, or studies that (1) have been conducted and evaluated in an objective manner by experts in the relevant disease, condition, or function to which the representation relates; and (2) are generally accepted in the profession to yield accurate and reliable results.” In addition, the FTC requires that the research must be “sufficient in quality and quantity based on standards generally accepted in the relevant scientific fields, when considered in light of the entire body of relevant and reliable scientific evidence, to substantiate that the representation is true.”7

For the reasons outlined above, DSSRC recommended that Urban Retreat take the necessary and good faith steps to ensure the removal of this social media post.



The Company’s Burden to Demonstrate a Good Faith Effort to Address the Earnings and Product Performance Claims

DSSRC recognized that several of the posts identified in this inquiry were several years old, originated outside the United States, and were authored by individuals no longer affiliated with the Company. Nevertheless, it is essential that direct selling companies demonstrate a good-faith effort to facilitate the removal of problematic social media posts, regardless of when or where those posts originated.

Although certain posts may be created by individuals outside the United States or may no longer reflect current business practices, such content remains accessible to a global audience—including U.S. consumers. These claims, even if outdated or unaffiliated with current operations, can influence purchasing decisions or shape perceptions of the business opportunity. By taking proactive steps to remove or address non-compliant content, companies help uphold industry standards, protect consumers from potentially misleading information, and reinforce their commitment to responsible marketing practices.

In such matters, DSSRC has recommended that companies document their attempts to contact the individuals responsible for the posts, and when unsuccessful, notify the hosting social media platforms that the posts: (a) contain earnings or product claims not authorized by the company; (b) remain accessible to the public despite outreach efforts; and (c) should be removed. DSSRC also notes that some companies have posted public comments clarifying that the content was not authorized and that removal has been requested.

Accordingly, if the Company is unable to persuade the individuals responsible for the posts to remove them, DSSRC recommended that Urban Retreat provide:

  1. Records of outreach to the individuals responsible for the posts and confirmation of any non-responsiveness;
  2. Copies of correspondence with social media platforms requesting removal of the posts; and
  3. If the social media platform permits, include language in the comment section of the posts clarifying that the posts were not authorized by the Company.



Conclusion

DSSRC concluded that it had jurisdiction over the matter and determined that the earnings and product performance claims in question conveyed unsupported messages regarding significant income potential and health benefits. The Company did not provide sufficient substantiation for the claims made in the identified social media posts. Therefore, DSSRC recommends that Urban Retreat take steps to facilitate the removal of these posts. If removal is not possible, the Company should demonstrate a good-faith effort to address DSSRC’s concerns by documenting outreach to the individuals responsible, requesting removal from the relevant platforms, and providing evidence of corrective action.



Failure To Provide Company Statement

Although DSSRC formally requested that Urban Retreat provide a Company Statement for inclusion in this report, the Company did not indicate any intent to comply with the recommendations set forth herein. Therefore, pursuant to Section VI(E) of the DSSRC Policies and Procedures, DSSRC has referred this matter to the Federal Trade Commission and the Office of the Illinois Attorney General for further review and potential law enforcement action.



(Case #238, closed on 09/26/25)
© 2025 BBB National Programs





[1] Pursuant to information maintained by the International Association of Better Business Bureaus, Inc.

[2] See Fed. Trade Commission, Business Guidance Concerning Multi-Level Marketing, Section 1 (January 2018).

[3] Fed. Trade Commission, Business Guidance Concerning Multi-Level Marketing, Section 1 (April 2024) https://www.ftc.gov/business-guidance/resources/business-guidance-concerning-multi-level-marketing#deceptive

[4] Direct Selling Self-Regulatory Council, Guidance on Earnings Claims for the Direct Selling Industry, Section 6 (2022). dssrc_guidanceonearningsclaimsforthedirectsellingindustry.pdf.

[5] See FTC Health Products Compliance Guidance at https://www.ftc.gov/system/files/ftc_gov/pdf/Health-Guidance-508.pdf, page 12.

[6] The Urban Retreat Detox Sip & Slim Bundle consists of two component products: Hydra Slim Plus and KetoCap Capsules.

[7] Supra at 5.