Online Product Claims: A Source and Disclosure Checklist Before You Buy

By MeridianMedicalCentre.com Health Research Team

Short answer: before you buy a health product online, separate four things for every claim you see: what the seller says, what source it points to, what the page leaves out, and the one question you can ask to check it. If you can't fill in all four, you have a reason to wait, and waiting costs nothing.

MeridianMedicalCentre.com is an independent consumer health research publication operated by MMC Research & Review. It is not a medical practice, clinic, or healthcare provider, and it is not affiliated with Meridian Health Group or any healthcare facility. Nothing here is medical advice. The “Medical Centre” in the domain reflects previous ownership history. Some pages on this site contain affiliate links; this article contains none. See Our Research Process for how we handle affiliate relationships.

Why a Checklist Helps

The Federal Trade Commission (FTC) says advertising must be truthful and not misleading, and that advertisers need adequate substantiation for objective product claims before they run an ad. That covers claims made expressly and claims suggested by implication. The FTC looks at the net impression of the whole ad, including text, product name, charts, and images, and not only at individual phrases.

That is a rule for sellers, but it works as a reading guide for buyers. A claim should come with support that matches it, and a page should disclose what a reasonable buyer would need to know.

One limit: the FTC describes its guidance as business guidance that does not have the force or effect of law and does not provide a safe harbor. Whether a specific ad is deceptive depends on the facts of the case. This article helps you read marketing more carefully. It cannot tell you whether a particular seller broke the law.

Step 1: Write Down the Claim Exactly

Copy the claim as it appears, along with where you saw it and the date. Then ask what else the page suggests without saying it outright. According to the FTC guidance, a marketer is equally responsible for claims a reasonable consumer would take from the ad, and images or a product name can imply more than the text does. A doctor-style image on a supplement page can suggest clinical proof. A product name can suggest that the product treats a disease.

Also note whether the claim is about normal body function or about a disease. The FTC says a statement about normal function can still imply a disease benefit, depending on phrasing and context.

Step 2: Identify What Kind of Source the Seller Cites

“Backed by research” tells you very little. The type of source matters. The FTC guidance says substantiation of health benefits generally needs randomized, controlled human clinical testing, and it describes other source types as weaker or insufficient on their own:

Randomized, controlled human trial of the actual product. The FTC describes this as the most reliable form of evidence. Check that the product, dose, and claimed benefit match what was studied.
Observational or epidemiological study. The FTC says these can show an association but do not prove a causal link.
Animal or test-tube (in vitro) study. The FTC says these may provide background but, without confirmation in human trials, are not enough for health claims.
Customer testimonials or surveys. The FTC says anecdotal evidence, including consumer surveys, is never sufficient to substantiate claims about a health product's effects.
A medical organization's general recommendation. The FTC says public health recommendations alone do not support a claim about a specific product.
Approval in another country. The FTC guidance gives an example where foreign approval did not by itself substantiate effectiveness.
“Traditional use.” The FTC says these claims need scientific substantiation unless carefully qualified, and the product must match the traditional form and use.

Step 3: Check Whether the Source Fits the Claim

Even a well-run study may not support what a seller says. The FTC guidance lists relevance questions for any cited study:

Do the dose and formulation match the product you would buy?
Was the same ingredient or combination tested, in the same form?
Does the measured outcome match the benefit advertised?
Do the study participants resemble the people the ad targets?

The FTC also points to basic quality markers in human trials: a control group, randomization, blinding where feasible, statistically significant results, and results large enough to matter to health. It notes that publication alone does not guarantee quality, because peer review rigor varies widely between journals. It warns against citing favorable studies while ignoring contrary ones, so it is reasonable to ask whether a seller is showing you all the relevant research or only one study.

You do not need to judge trial design yourself. The FTC says that task calls for someone with appropriate expertise. What you can do is notice when a seller gives no study at all, or offers only an abstract, a general article, or a testimonial.

Step 4: Look for What the Page Leaves Out

The FTC says an ad can be misleading because of what it fails to say. Information that is material in light of the claims may need to be disclosed, including significant limits on a benefit and significant safety risks. Its examples include medication interactions and side effects that an ad's wording implies are absent.

Limits on the benefit. Does the claim apply only to people with a specific deficiency or condition?
Safety information. Are risks, side effects, or interactions with prescription medicines mentioned anywhere you can easily find?
Buried qualifiers. The FTC says disclosures should be clear and conspicuous, and that a fine-print statement cannot fix a claim it contradicts.
Vague hedges. The FTC says words like “may,” “helps,” “promising,” or “preliminary” are often inadequate to convey the limits of the science.
Regulatory wording. The FTC says advertisers should not mischaracterize how far the FDA has reviewed or approved a product or claim. The two-part DSHEA disclaimer required on supplement labels does not make an otherwise deceptive ad acceptable. If you see “FDA approved” or “cleared,” ask exactly what was reviewed, for what purpose, and for which claim.
Typical results. For testimonials with dramatic outcomes, the FTC says “results not typical” does not cure the problem and that typical expected results should be disclosed clearly.
Guaranteed or miracle results. The FTC's consumer advice says a product that guarantees miracle results may be a scam.

Step 5: Check Who Is Behind the Recommendation

The FTC guidance says any expert or consumer endorser's material connection to the seller should be clearly and conspicuously disclosed. A material connection is a personal, financial, or similar tie that consumers would not reasonably expect. Its examples include paid bloggers and sites that look independent but are owned by the advertiser.

Is there a clear statement of whether the writer earns money if you buy?
Is the disclosure near the recommendation, or hidden on another page?
Does the “independent” site or expert have a stated tie to the seller?

That applies to us as well. Where an article on this site contains affiliate links, it carries a disclosure, and Our Research Process explains our method and its limits. We do not test products in a laboratory, we are not a regulator, and our verdicts are editorial opinions. Treat any review, including ours, as one input, not as proof.

The Claim-Source-Disclosure Worksheet

Use one copy per claim, on paper or in a notes app.

The claim, word for word. Write the exact words, the page address, and the date. Add any implied claim from images, the product name, or the context.
Source type cited. Choose one: human controlled trial of this product; human study of a related ingredient; observational study; animal or lab study; testimonials or survey; general health recommendation; foreign approval; traditional use; nothing cited.
Does the source fit? Note whether dose, form, population, and outcome match the claim. Write “unknown” where the page does not say.
What is missing. List absent limits, safety information, interaction warnings, typical-results information, or an explanation of what a regulatory term means.
Who benefits. Write who earns money if you buy, and whether the page says so near the recommendation.
The verification question. Write one specific question, for example: “Can you provide the full study of this exact product, including dose and number of participants?” Send it to the seller and note whether and how they answer.
The no-purchase route. If any answer is missing, decide what you will do instead: save the page or a screenshot with the date, do not buy, and take your worksheet to a pharmacist or doctor. If a page looks like a health product scam or misleading advertising, you can report it to the FTC.

Worked Examples Based on FTC Illustrations

These are hypothetical scenarios from the FTC guidance, not real products.

“Scientists now agree!” Claim: a supplement's benefit has reached scientific consensus. Source cited: none. Missing: any evidence of consensus. The FTC says such a statement is false unless the advertiser has evidence that scientists actually reached consensus. Verification question: which scientific body or review reached that conclusion?
“Clinically tested ingredient.” Claim: an ingredient improves endurance. Source cited: a test of the ingredient alone. Missing: whether the finished drink, with its other ingredients, was tested. The FTC says the phrase can imply proven benefits, and that experts may require testing of the actual product.
“75% of customers noticed improvement.” Source cited: a customer satisfaction survey. The FTC says survey results, even accurately reported, are anecdotal and cannot substantiate a benefit. Missing: any controlled human study.

Seller Terms: Check Them at the Source

Return, refund, and cancellation terms change and differ by seller. Read the current terms on the seller's own checkout or policy page before paying, and save a copy. In a June 2020 consumer alert about an FTC settlement, the FTC said one company advertised risk-free, money-back guarantees, but some costs and fees were not refundable and the refund process was difficult, so many customers received no refund or waited a year or more. That is the FTC's account of one case, but it shows why to ask before you buy: what exactly is refundable, what does a return cost, and how long does a refund take? Do not rely on a review, including ours, for current terms.

Who Should Get Professional Advice First

Talk to your doctor or pharmacist before using a health product if any of these apply:

You take prescription medicines. The FTC guidance gives examples of products that can interact with medications or cause side effects the marketing does not mention.
You are managing a serious condition. The FTC warns that unsubstantiated treatment claims can lead people to forgo more effective care.
A page claims a product treats, cures, or prevents a disease.
A product claims to be FDA approved or cleared. The FTC's consumer advice is to talk to your doctor's office before using any healthcare product, even one making that claim.

Do not stop or change a prescribed treatment because of something you read online, including this article. Ask the prescriber first.

Where to Go Next on This Site

Consumer Guides for frameworks on label reading and marketing language.
The Evidence File for ingredient-level and claims-level evidence reviews.

Sources

Federal Trade Commission, Health Products Compliance Guidance (December 2022). Supports the statements on substantiation, implied claims, evidence types, relevance, disclosures, DSHEA disclaimers, FDA wording, endorsements, material connections, and the guidance's legal status.
Federal Trade Commission, Health product claims and false guarantees, Consumer Advice (June 2020, last modified June 2022). Supports the statements on the alleged refund problems, talking to a doctor's office before using any healthcare product, and miracle-result guarantees.

Sources last checked October 1, 2026. This article is educational, is not medical or legal advice, and reflects publicly available information at that date. Guidance, seller policies, and products change, so verify current details directly.