Case #11-2020 – Monitoring Inquiry – Dose of Nature
BBB NATIONAL PROGRAMS, INC.
The Direct Selling Self-Regulatory Council
Case Number: 11-2020 – Monitoring Inquiry – Dose of Nature
BASIS OF INQUIRY
Dose of Nature (“Dose of Nature” or the “Company”) is a multi-level direct selling company that offers water-soluble CBD and nano CBD products for humans and animals.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs, Inc. This inquiry was commenced by the DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Specifically, DSSRC identified the following product performance claims being disseminated on the social media pages of certain Dose of Nature distributors for the Company’s line of CBD products.
- Thank you, Dose of Nature! He’s living proof that CBD cures seizures. Not one in over a year. Redstrap CBD had been a [m]iracle!” Ava C.
- “CBD Oil Helps with:
Etc, etc, etc…”
- “CBD works for pets”
- “BFF Select CBD is amazing for all pets and animals. Scale dosage as necessary for weights and the conditions as necessary.”
- “CBD for dogs is EXACTLY THE SAME as CBD for humans. The only DIFFERENCE IN DOSING is because of the body weight
THERE IS NO DANGER OF OVERDOSING
but the trick is to start with the lowest dose and then find the sweet spot for your particular dog”
- “Relief from pain, stress, anxiety give you that get-up-and-get-going feeling. BFF Select CBD specifically formulated for the BFF in your home”
REFERRAL TO GOVERNMENT
On November 18, 2019, pursuant to its ongoing, independent monitoring of advertising and marketing claims in the direct selling industry, DSSRC sent Dose of Nature its opening letter in which DSSRC identified the aggressive product performance claims stated above that are disseminated on the social media pages of certain Dose of Nature distributors regarding the efficacy of its CBD product to treat severe health related conditions in humans and to provide health benefits to pets and animals.
Pursuant to the DSSRC Policies and Procedures, the Company was provided fifteen (15) business days to respond to DSSRC following its receipt of the DSSRC November 18, 2019 opening letter. Unfortunately, the Company failed to respond to DSSRC’s initial correspondence. Subsequently, after repeated attempts to contact the Company by telephone and email, DSSSRC sent a follow up letter to the Company on January 7, 2020 expressing its concerns with the claims identified in DSSRC’s opening letter and requesting substantiation for such claims on or before January 22, 2020. However, despite DSSRC’s ongoing attempts to contact the Company, it again failed to respond to DSSRC’s inquiry.
Section (D)(I)(9) of the DSSSRC Policies & Procedures states that if a company does not respond to DSSRC, or declines to participate in the DSSRC process, DSSRC will issue a case decision indicating that the company was unresponsive or declined to participate in the DSSRC process and may refer the matter to appropriate government agencies.
Accordingly, based upon the aggressive nature of the product performance claims at issue and the failure of the Company to respond to DSSRC, this matter has been referred to the Federal Trade Commission pursuant to the DSSSRC Policies & Procedures.
(Case No. 11-2020 PCM, closed on 01/31/20)
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