Case #196-2025: Monitoring Inquiry - Zinzino, LLC

BBB NATIONAL PROGRAMS

Direct Selling Self-Regulatory Council
Case #196-2025: Monitoring Inquiry - Zinzino, LLC

 

Company Description 

Zinzino, LLC (“Zinzino” or the “Company”) Zinzino is a direct-selling company founded in 2005 that specializes in health and wellness products, primarily focused on omega-3 supplements, skin care, and functional foods. The Company is headquartered in Frölunda, Sweden and has a subsidiary in Jupiter, Florida.

Basis Of Inquiry

The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry. 

DSSRC was concerned that the representative claims below communicate the message that the typical Zinzino salesforce member can generally expect to earn significant income from the Company’s business opportunity and that Zinzino products are efficacious in addressing serious health-related conditions.

The online claims at issue were disseminated on YouTube, Facebook, LinkedIn, and Instagram.

Earnings Claims

  1. Video of incentive trip. “Luxury in a class by itself. Exotic Touch in a 5-star hotel.” (07/2020)
  2. “What better way to earn a part-time or full-time income than by sharing business and product stories? You decide how much you work and how far you go. My team and I are here to support you along the way. Work as much as you want. Earn as much as you want. We call it freedom.”
  3. “Regain your health and secure a financial freedom.” (07/2022)
  4. “She has been building uh the zenzino business here in the united states um building a grand business making an incredible income …”
    • “… if you want to create an income of fifteen hundred dollars every month …”
    • “… if you understood residual income you'd walk through a brick wall to get it then xeno has a huge residual Opportunity …”
    • “so he hasn't worked in a whole year a whole year with no income zero zero and now she's paying for all the bills for every single bill that she can pay thanks to zenzino.”
    • “… we're helping you know healthy with money financially healthy absolutely helping people financially healthy.” (03/2021)
  5. “Have you thought about your new years ‘goals?’ Is it better health? financial freedom?” (12/2021)
  6. “You can immediately start your business venture with minimal financial risk. It is free to join and you get discounts from your first order. What better way to earn a part-time or full-time income, than by sharing and selling products you love?” (01/2022)
  7. “Huge congrats to Emeterio Lopez III for achieving Smart Bronze & X-Team Express in 1 day. $400.00+” (11/2021)
  8. “🌲 Financial freedom & laptop lifestyle” (05/2021)
  9. “And I’m ready to help people getting their body in balance and help people get financially freedom.” (05/2022)
  10. “🚀 Generate A Side Or Full Time Income Helping People Feel Awesome” (05/2024)
  11. “Unlock Your Potential with Zinzino: Join the Health and Wealth Revolution! … Lucrative Income Potential: Our business model provides a flexible and rewarding income opportunity. Whether you’re looking for a side hustle or a full-time career, Zinzino offers the potential for substantial financial rewards.” (06/2024)
  12. “I’ve been asked before how do I make $1000 a month or $10,000 a mo in biz. Finally, here is the answer:
    • Fast start = (10 products sold, sponsor 2, help them sponsor 2) = $3000 first month.*
    • A Fast Start (volume) = Silver
    • 4 Silvers = 4 Executives ($1000 a mo residually).
    • 4 Executives = Diamond ($5000 a mo residually). Also, car allowance $1150 a month.*
    • 4 Diamonds = Crown. Minimum $13,000-$20,000 a month. …
    • *You get a trip for two every year for 7 days, somewhere globally (Spain, Italy, next is in Thailand) by maintaining Director rank.” (07/2024)


     

Product Performance Claims

13. “Also, a 100% success rate when it comes to people's health. 🙏 God is good!!!” (07/2022)

14. “Lower bad cholesterol, Strength Immune System, Improve Brain Function.” (06/2023)

15.“Help reduce inflammation in your body with our proven (yes proven) test-based nutrition.” (06/2023)

 

Company’s Position

 Zinzino did not attempt to substantiate the claims identified by DSSRC and instead took action to contact the salesforce members who were responsible for the online posts and requested that the posts be removed.

The Company was successful in removing 14 social media posts and modified one post to remove the claim at issue.

Zinzino explained to DSSRC that it ensures that its salesforce members disseminate compliant claims through a structured approach that includes both training and monitoring.

Specifically, the Company stated that it provides a comprehensive "Marketing Rules & Ethics" document that all Independent Partners are required to understand and comply with. This document outlines the company's policies, including the proper use of trademarks and guidelines for marketing practices.

In addition, Zinzino stated that it offers digital training and information, including Business Ethics Guidelines, accessible to all employees and distributors via the company's intranet and invests in training new distributors on ethical regulations to prevent violations. These resources are designed to educate partners on ethical regulations and compliance standards. The Company explained that new partners receive guidance from mentors and a supportive team, providing the necessary training to succeed and adhere to company standards.

Zinzino also noted that it provides internal monitoring of the claims made by its salesforce members, which ensures that the Company's practices align with industry standards and regulations.

The Company asserted that through this combination of comprehensive training programs and diligent monitoring, Zinzino strives to maintain high standards of compliance and ethical conduct among its salesforce members.

Analysis and Recommendation

DSSRC expressed its appreciation to Zinzino for its good faith efforts in removing 14 social media posts that were the subject of the inquiry and modifying one post to remove the claim at issue. DSSRC determined that the Company’s actions were necessary and appropriate.

Earnings Claims

In addition to several express claims communicating that the typical Zinzino salesforce members can earn significant income (e.g., “fifteen hundred dollars every month”), DSSRC also identified various posts that included claims that salesforce members could earn “unlimited income” and achieve financial freedom through participation in the Company’s business opportunity.

As stated in the Federal Trade Commission’s (FTC) Business Guidance for Multi-Level Marketing (“the FTC Guidance”), “any earnings claim should reflect what the typical person to whom the representation is directed is likely to achieve in income, profit, or appreciation.”1 Moreover, “[a]n MLM or participant making claims about MLM income must have a reasonable basis for the claims disseminated to current or prospective participants about the business opportunity at the time it makes the claims.”2 The FTC Guidance further notes that given the reality of MLM experiences, even truthful testimonials of individuals who earn large amounts of money or career-level money is atypical to the what most MLM participants will achieve.3 Therefore, presenting atypical earnings “is likely to generate a deceptive impression” of the earning potential of a given business opportunity.4

The DSSRC Guidance on Earnings Claims for the Direct Selling Industry (“the DSSRC Earnings Claim Guidance”) addresses the issue of "unlimited income" claims by stating that such claims should be avoided when communicating with prospective or current salesforce members.5 The DSSRC Earnings Claim Guidance explains that some words and phrases are prohibited when made to a general audience of prospective or current salesforce members. Such words and phrases include statements such as “quit your job,” “be set for life,” “make more money than you ever have imagined or thought possible,” “unlimited income,” “full-time income,” “replacement income,” “career-level income,” or any substantially similar statements or representations.6 The DSSRC Earnings Claim Guidance further notes that “[s]ome words or phrases carry a particularly high risk of being misleading to consumers when communicated in a general context. Such words and phrases include but are not limited to “financial freedom…”.7

With respect to incentive-based claims pertaining to trips and bonus rewards, the DSSRC Earnings Claim Guidance recommends that, if salesforce members do not typically receive such incentives and rewards, that the post should include a clear and conspicuous disclosure in close proximity to the claim highlighting the number of salesforce members who typically receive the incentive or reward.8

In the subject inquiry, Zinzino took action to contact the salesforce members responsible for the earnings claims identified by DSSRC and was successful in having all 12 social media posts removed.

Product Claims

It is well-established that claims concerning the efficacy of health products should be supported by competent and reliable scientific evidence. In its recently published Health Products Compliance Guidance, the FTC defines competent and reliable scientific evidence 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.”9 The FTC also requires that 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.”10 

Zinzino did not dispute that the Company’s products were not intended to diagnose, treat, cure, or prevent any disease. The Company did not provide any testing data to DSSRC indicating that its products are effective at lowering bad cholesterol, measurably strengthening the immune system, improving brain function, and reducing inflammation. In the absence of such data, DSSRC agreed that the Company’s efforts to remove these posts from the respective social media platforms were warranted.

Accordingly, DSSRC appreciated the actions taken by Zinzino to remove two of the social media posts that communicated unsupported performance claims and modify the remaining post to eliminate the language stating that Zinzino products provide “a 100% success rate when it comes to people's health.”

Conclusion

Based upon Zinzino’s good faith efforts to remove the 14 social media posts identified by DSSRC in this inquiry that communicated unsupported earnings and product performance claims and the Company’s modification of the remaining post to remove the claim referencing “a 100% success rate when it comes to people's health[,]” DSSRC administratively closed its inquiry.

Company Statement

“Zinzino is fully committed to truthfulness and transparency when promoting our business opportunity. We take great care in following all rules and regulations, as fostering a strong culture of compliance is essential to our values. Our favorable reputation with consumers and industry peers alike is a source of great pride for us and something we strive to protect.

To further strengthen our compliance efforts, we have implemented tools to proactively monitor our Independent Partners, ensuring they adhere to our ethical and regulatory standards. Additionally, we are continuously improving our compliance framework and are excited to launch our new Marketing Rules and Ethics Policy in Q2 2025.

We will continue to identify and act on opportunities to enhance compliance training and provide valuable tools to our sales force, ensuring they uphold the highest ethical standards in every aspect of their work.”

(Case No. 196, Closed on 2/20/25)
©2025. BBB National Programs

 

[1] See Fed. Trade Commission, Business Guidance Concerning Multi-Level Marketing, Section 13 (April 2024) https://www.ftc.gov/business-guidance/resources/business-guidance-concerning-multi-level-marketing#deceptive.

[2] Id.

[3] Id. at Section 13.

[4] Id.

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

[6] Id. at Section 6.

[7] Id. at Section 6(A).

[8] Direct Selling Self-Regulatory Council, Guidance on Earnings Claims for the Direct Selling Industry, Section 8(B) (2022). dssrc_guidanceonearningsclaimsforthedirectsellingindustry.pdf

[9] Fed. Trade Commission, Health Products Compliance Guidance, Section B. Substantiating Claims, 12.  https://www.ftc.gov/system/files/ftc_gov/pdf/Health-Products-Compliance-Guidance.pdf

[10] Id.