DSSRC Administrative Closure #238
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding six social media posts that were disseminated on social media and that were identified by DSSRC pursuant to its ongoing, independent monitoring of the direct selling industry. DSSRC was concerned that the posts communicated health-related product claims including those regarding the human body’s immune system that could be interpreted as implied claims that the Company’s products protect against COVID.
After commencement of the inquiry, DSSRC engaged in dialogue with the Company and explained the basis of DSSRC’s concerns. In response, the Company promptly contacted the individuals responsible for the posts and was successful in effectuating the discontinuance of five of the six posts. The one remaining social media post was disseminated by a former salesforce member who was not responsive to the Company’s request that the post be removed. The Company demonstrated to DSSRC that it made a good faith effort to effectuate removal of the remaining post, but its attempts were unsuccessful.
In addition, the Company informed DSSRC that it would update its training, monitoring, and enforcement of its salesforce members to provide greater clarity and guidance regarding health-related product claims regarding the human immune system so as to avoid the dissemination of any implied disease prevention and/or treatment claims.
Based upon the Company’s bona-fide efforts to address DSSRC’s concerns, DSSRC administratively closed this inquiry.
(Administrative Closure #238, closed on May 2, 2022)
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