Case #154-2024: Administrative Closure – Unicity International

BBB NATIONAL PROGRAMS

Direct Selling Self-Regulatory Council
Case #154-2024: Administrative Closure – Unicity International

Company Description

Unicity International ("Company") is a multi-level direct selling company headquartered in Provo, UT and founded in 1986 that sells nutritional supplements and self-care products.

Basis of Inquiry

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

This inquiry concerned 13 product performance claims. DSSRC was concerned that the representative claims below communicated the message that the Company’s products are efficacious in addressing serious health-related conditions. The social media posts at issue were disseminated on Facebook, Twitter, TikTok, and Instagram.

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

• 18 pounds, 7 inches off of my body, no more acid reflux, my PCOS has been significantly improved, my periods have now become regulated. I’m feeling incredible, I don’t have fatigue anymore, I have tons of energy, I’m sleeping better, my mood is better so my anxiety is super low now 
  • Before and after images of weight loss 
• Video of blood sugar results with audio stating “it’s the results for me, look at that. You can’t beat it. Unicity, get on it.” 

  #hormoneimbalance #insulinresistance 

• “How I lost 20lbs in 2 months”  
• “The best way i seen to manage #wheight, #diabete, #hormoneinbalance &  restore #metabolicprocess” 
• “My Unicity Journey to get off Diabetes Medication #diabetes #insulinresistance #type2diabetes” 
• “THE NATURAL GASTRIC BALLOON COMBO TOGETHER WITH OUR FAT BURNER helps you 

  🚨Diabetes 

  🚨Neuropathy 

  🚨Cholesterol 

  🚨Thyroid 

  🚨Menopause 

  🚨Fibromyalgia 

  🚨Arthritis 

  🚨Rheumatoid Arthritis 

  🚨Lupus 

  🚨Fatty Liver 

  🚨Inflammation 

  🚨Hypothyroidism 

  🚨Migraines 

  🚨Anxiety 

  🚨High Pressure 

  🚨Auto Immune Diseases 

  🚨Asthma 

• Feel Great System helps to: 

  👍Diabetes control 

  👍Cholesterol control 

  👍Adjust blood pressure 

  👍Support focus, memory and mood 

  #diabetes #diabetesmanagement #cholesterol #bloodpressure #bloodsugar 

• “I controlled my pre diabetes high cholesterol lost fat and then started sharing feel great with others I’ve built a multi million dollar business without overhead and headaches giving financial freedom to be a dad #insulinresistance #diabetes” 
• “Do you know  anyone who wanna lose weight with changing ur diet Unicity  helps with all that plus high cholesterol high blood pressure ect” 
• “Feel Great System helps to: 
  👍Diabetes control 
  👍Cholesterol control 
  👍Adjust blood pressure 
  👍Metabolic Health Renewal  

  #weightloss #weightlosssolutions #diabetesmanagement #cholesterol #diabetes #arthritis #inflammation” 

• “You can reverse diabetes you Can reverse high blood pressure” 
• Image with copy stating “Benefits of Unimate and Balance: High Cholesterol; Diabetes; Thyroid; Fatty Liver; PCOS; Tummy fat; HIGH B.P.; Migraine; Body Pain” 
• “… lower cholesterol ad blood sugar levels, diabetes prevention, reduced anxiety and depression, better focus” 

Company Position

Following its receipt of the DSSRC inquiry, Unicity promptly began contacting the individuals responsible for disseminating the social media posts to request that the claims be removed or modified, resulting in the successful removal of 11 of the claims at issue.

The Company further informed DSSRC that it attempted to contact the individuals responsible for the two remaining posts that were the subject of the inquiry and requested that they remove the noncompliant posts. The Company also terminated the accounts of salesforce members that were unresponsive to the Company’s requests to remove or modify the posts at issue. In addition, the Company added publicly viewable comments on remaining posts made by terminated salesforce members noting their unauthorized nature and contacted the social media platform on which the claims appeared to request that such unauthorized posts be removed.

Administrative Closing Summary

DSSRC appreciated the actions taken by Unicity to effectuate the discontinuance of all but two of the health-related social media posts at issue and determined the Company’s actions to be necessary and appropriate.

The FTC expects that advertisers have a reasonable basis for all product claims and the standard of substantiation for health-related product claims is particularly rigorous. The FTC has defined the health claim substantiation standard as requiring “competent and reliable scientific evidence” in the form of “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.” Health claim substantiation evidence must generally take the form of randomized, controlled human clinical trials (“RCT”), with animal and in vitro studies generally being insufficient without RCT confirmation, and anecdotal evidence being insufficient. Moreover, the evidence relied upon must be relevant to the advertised product with respect to, among other things, dosage, formulation, and method of administration.¹

In the absence of such information, DSSRC concluded that the Company took the appropriate action to effectuate the removal of the removal of the social media posts at issue.

With respect to the two posts which remain publicly accessible on social media, DSSRC determined that the Company made a verifiable, good-faith effort to have the two remaining posts removed or modified.²

Accordingly, based upon the Company’s good faith efforts to address the claims identified in this inquiry, DSSRC administratively closed the inquiry.  

Conclusion

DSSRC administratively closed this inquiry based on the Company's demonstrated good faith actions in addressing the issues brought to its attention. More specifically, DSSRC determined that the Company made a bona fide, good-faith effort to address its concerns by promptly removing eleven of the identified posts and taking appropriate actions to have the other two removed or modified.

(Administrative Closure #154, closed on 04/09/24)
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[1] Elomir, Inc. (Case #139-2023).