Direct Selling Self-Regulatory Council (DSSRC)
Direct Selling Self-Regulatory Council Refers Health-Related Product Claims Disseminated by Dose of Nature to the Federal Trade Commission
New York, NY – February 7, 2020 –The Direct Selling Self-Regulatory Council (“DSSRC”) has referred certain marketing claims made by Dose of Nature (“Dose of Nature” or the “Company”) for its water-soluble CBD and nano CBD products for humans and animals to the Federal Trade Commission for possible enforcement action after the Company failed to participate in the DSSRC self-regulatory forum. The health-related product claims at issue in DSSRC’s inquiry were regarding product efficacy for animals and humans as well as claims that certain Dose of Nature can treat specific diseases such as Tourette’s Syndrome and Crohn’s disease.
DSSRC is the direct selling industry’s self-regulatory forum and a division of BBB National Program, Inc.’s self-regulatory and dispute resolution programs. The subject marketing for Dose of nature came to the attention of DSSRC through its own independent monitoring. Specifically, DSSRC requested substantiation for the health-related product claims made by the Company and its salesforce members.
The health-related claims reviewed by DSSRC were representative examples of those made generally in the marketplace on behalf of Dose of Nature and included:
- 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.
- #painfree #siezurefree
- “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”
In November 2019, DSSRC sent Dose of Nature its opening letter in which DSSRC identified the product performance claims stated above that were disseminated on the social media pages regarding the efficacy of the Company’s CBD products to treat severe health related conditions in humans and to provide general health benefits to humans 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. 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. However, despite DSSRC’s ongoing attempts to contact the Company, it 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 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.
About the Direct Selling Self-Regulation Council (DSSRC): Direct Selling Self-Regulation Council (DSSRC), a division of BBB National Programs, provides independent, impartial, and comprehensive monitoring of direct selling companies on an industry-wide basis and addresses product claims and income representations (including lifestyle claims) by companies and salesforce members with an emphasis on claims disseminated on social media platforms.
About BBB National Programs: BBB National Programs fosters trust, innovation, and competition in the marketplace through the development and delivery of effective, third-party self-regulation, dispute resolution and other programs. BBB National Programs is the home of industry self-regulatory and dispute resolution programs that include the National Advertising Division (NAD), National Advertising Review Board (NARB), BBB EU Privacy Shield, BBB AUTO LINE, Children’s Advertising Review Unit (CARU), Children’s Food and Beverage Advertising Initiative (CFBAI), Children’s Confection Advertising Initiative (CCAI), Direct Selling Self-Regulatory Council (DSSRC), Digital Advertising Accountability Program (Accountability Program), and the Coalition for Better Advertising Dispute Resolution Program (CBA DRM). The programs are designed to resolve business issues and advance shared objectives by responding to marketplace concerns to create a better customer experience. To learn more about industry self-regulation, please visit: BBBNP.org.