OTCs in Action Episode 5: Thinking about Brain Health


This month, US Federal Trade Commission Chairwoman Edith Ramirez cautioned marketers of brain health supplements that the National Advertising Division is watching them. In a keynote speech at the NAD’s conference, Ramirez said companies who conduct false and misleading marketing campaigns for these products prey on consumers’ fears of ageing and hope for their children. The agency has prioritised taking action on companies that take advantage of consumers this way.

For example, the NAD’s latest action targeted SmartX from Cerebral Success, which has agreed to refrain from making a wide range of claims, such as “Cerebral Success was specifically designed as a study pill to provide an Adderall alternative for students who are taking the drug without a prescription. It is not, however, designed to treat the condition. Along with focus and mental energy (the hallmarks of Adderall), Cerebral Success was designed to increase memory and strengthen and protect the brain, which Adderall does not do.”

This type of borderline disease claim-making is so damaging to the credibility of a category that can truly help people. In fact, brain health has been hailed as the next big dietary supplement boom. Therefore, we spotlight this week’s OTC in Action, i-Health’s BrainStrong Memory Support, which has been reformulated and relaunched after reaching a settlement with the NAD regarding previous claims for cognition and memory health. Legal analysts say the settlement requires that the quality and quantity of scientific evidence must prove the specific claim for the brand, a departure from the two-study standard previously accepted. The order also includes a provision that data is collected and documented by the company.

BrainStrong’s new positioning has undergone trial by fire:

BrainStrong Memory Support is a breakthrough new formula containing gingko biloba and choline – two ingredients scientifically demonstrated to help support brain signals, sharpen focus and support a healthy memory. The website also encourages consumers to “Support your memory … and save money too!”

And the lower cost should encourage trial by consumers!

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