The ClickBank Claims Guide is built for Sellers and provides guidance and recommendations to be used when creating, writing, adjusting, or editing claims within their marketing copy that will hep ensure claims are complaint with FDA and FTC guidelines.
As a ClickBank Seller, your copy and claims are ultimately your responsibility. However, ClickBank will review your copy to help lower your risk level. To sell your product on ClickBank, your copy must be approved by our compliance team.
NOTE: Keep in mind that this guide is not comprehensive or final. The net impression surrounding your statements is also important. For example, while you might use a word that on its face is compliant, the context of your statement could cause that statement to become non-compliant because it is implying a disease state. We encourage you to use this guide as a framework to come up with more creative and compelling ways to market a claim compliantly.
Dietary Supplements
Dietary supplements may not claim to diagnose, treat, cure or prevent a disease or symptoms of a disease. All claims made in regards to a dietary supplement must start from a point of health and support a structure or function of the body.
Common Claims
Acceptable | Avoid |
Maintains | Treats |
Supports / Assists | Cures |
Promotes | Prevents |
Supplementation regime for | Therapeutic |
Supplements the diet | Medicinal / Treatment |
Formulated to promote / maintain health and well-being | Pain |
Supports a healthy response to stress | Stress disorders |
Supports coping with occasional blues associated with everyday life / resolving that irritability that ruins your day | Chronic Anxiety / Depression / Panic Attacks |
Promotes calmness and relaxation | PTSD / Stress |
Supports a positive, healthy mood / Improves mood / helps reduce stress and tension | Bipolar / Depression |
Helps with muscle pain due to exercise | Anti-inflammatory / Inflammation |
Supports a healthy inflammatory response following exercise / Supports the body's inflammatory response | Anti-inflammatory / Inflammation |
Supports healthy cartilage and joint mobility | Arthritis / Joint pain |
Supports the body’s natural sleep cycle | Solves sleep problems |
Supports quality / optimal sleep | Alternative to sleeping pills / Medication |
For occasional sleeplessness | Insomnia |
Helps with weight management or exercise | Lose weight without dieting |
Helps maintain healthy blood sugar levels | Lowers blood sugar levels |
Helps maintain cholesterol levels within a normal range | Lowers cholesterol levels |
Alleviates occasional constipation | Alleviates chronic constipation |
Promotes sexual arousal and performance | Eliminates male impotence problems |
Helps maintain proper immune system function | Stimulates the body’s antiviral capacity |
Helps maintain intestinal flora | Helps individuals using antibiotics maintain normal intestinal flora |
Improve the feeling of your hair | Secret to thicken hair |
Supports Hair Growth | Reverse thinning hair |
Leave your hair feeling rejuvenated and more beautiful, less dry and dull | Breakthrough to regrow hair |
Lose up to 3 pounds in 7 days (any multiple of this, like 12 lbs in a month, etc.) | Lose 3 lbs literally overnight, lose up to 45 lbs in 90 days |
Supports the body’s immune system | Supports the body's antiviral capabilities |
Arouses or increases sexual desire and improves sexual performance | Restores your sexual performance and staying power |
Cosmetics
Cosmetic products may not claim to repair, treat, cure, or prevent a disease or symptoms of a disease. All claims made in regards to a cosmetic are able to cleanse, moisturize, beautify, promote attractiveness or alter the appearance of the skin, which is otherwise supporting a structure or function of the skin.
Common Claims
Acceptable | Avoid |
Keeps your skin looking healthy | Pain / Pain Relief |
Hydrating | Anti-inflammatory |
Moisturizing | Relieves inflammation |
Reduces or minimizes the appearance of wrinkles | Anti-aging |
Helps to minimize the appearance of wrinkles | Heals skin |
Hides skin imperfections | Repairs skin or skin damage |
Reverse the signs of aging | Reverse years of aging on your skin |
Helps to improve the appearance of age spots | Eliminates wrinkles and dark spots |
Make your wrinkles appear more smooth and your sagging skin more plump and hydrated / hydrates the skin which promotes skin elasticity | Prevents wrinkles |
Revitalizes / Replenishes skin or hair | Eliminates skin imperfections |
Smooths and softens skin | Eliminates age spots or skin discoloration |
Nourishes skin or hair | Correct the effects of sun damage on skin |
Improves appearance of skin texture and elasticity | Increases skin elasticity |
Supports / provides a more youthful appearance | Prevents aging |
CBD Products
NOTE: All claims guidance above also applies to CBD products.
The Food and Drug Administration does not currently view CBD as a legal dietary ingredient to be included in dietary supplements or foods. The FDA is currently working to create a legal framework and guidance materials for labeling and cGMPs specific to ingestible CBD products which the FDA is expected to adopt in the near future. Until that happens, ClickBank will accept for review only CBD products in a topical/cosmetic form.
Common Claims
Acceptable | Avoid |
Broad or full spectrum hemp extract, depending on the ingredient used | Improves |
Sourced from high-quality hemp | Pain Relief |
| Proven effective |
| Restores |
| Repairs |
| Therapeutic |
| Healing |
| Treatment or Cure |
Examples
For OTC Cosmetics with ingredients aligned with approved FDA Monograph, claims must be attributed to the active ingredient(s) and not to CBD.
Active Ingredient | Concentration Range | Allowable Claims per FDA Monograph | Avoid |
Menthol and/or Camphor | 0.1 – 16% 0.1 – 11% | For the temporary relief of minor aches and pains of muscles and joints” [which may be followed by: "associated with” (select one or more of the following: "simple backache,” “arthritis,” “strains,”"bruises,” and “sprains." | Attributing allowable claims to CBD |
Chronic pain | |||
Permanent Pain Relief | |||
Anti-inflammatory | |||
Relieves Inflammation | |||
Cures or Heals | |||
Repairs | |||
Replaces X Drug |
Acceptable Verbs
Acceptable Verbs | Avoid Verbs |
Augments | Cures |
Improves | Diagnose |
Lowers | Mitigates |
Maintains | Prevents |
Modifies | Treats |
Promotes |
|
Raises |
|
Reduces |
|
Regulates |
|
Restores |
|
Revamp |
|
Revitalize |
|
Stimulates |
|
Strengthens |
|
Supports |
|
Optimize |
Allowed:
Videos and testimonials containing actors who portray consumers and describe their success using the product are only allowed if the video accurately portrays a typical customer experience, and includes disclaimer appearing with the actor making such a disclosure (ex: “Actor Portraying Real Purchaser”).
Clearly and conspicuously disclose the generally expected performance in the circumstances shown in the ad.
Videos and testimonials containing actors telling the seller's actual experience/story (either 1st or 3rd person) are allowed, but must include a clear and conspicuous disclaimer identifying the fact that it is an actor portrayal. Please also see the section below entitled Disclosures & Disclaimers for more information. A text disclaimer alone is not adequate.
Videos and testimonials containing a spokesperson describing the product’s actual attributes (must use a disclaimer).
Videos and testimonials containing an actual customer telling their actual story (does not require a disclaimer, but seller must have signed documentation from the customer on hand in the event a regulatory agency would want proof that the story is a customer’s actual experience).
Videos and testimonials containing the actual seller telling their actual story (does not require a disclaimer).
Not Allowed:
Videos that portray or reference a fictionalized individual or life story, where a seller makes false claims as part of the product pitch, are prohibited.
Videos that portray or reference the seller, where the seller makes false claims about their earnings, are prohibited.
Videos that don’t allow viewers to exit or pause are prohibited.
Endorsements without substantiation are prohibited.
Videos (including images and voice overs) that utilizes or replaces one’s likeness are prohibited.
Note: Any claims contained in the video must be capable of substantiation. Sellers must understand that if the FTC, private litigant or other agency asks for substantiation, the seller must have proof to back up any claim made in the seller's video.