Helpful Reminders from Modere Compliance Department

Product Claims

In Stephen Sondheim’s musical adaptation of Sweeney Todd, Tobias Ragg, an apprentice of a barber and entrepreneur, Adolfo Pirelli, is trying to advertise and sell Pirelli’s unconventional homemade elixir that he claims to grow hair:

[Tobias]

Ladies and gentlemen
May I have your attention please?
Do you wake every morning in shame and despair
To discover your pillow is covered with hair
What ought not to be there?

Well, ladies and gentlemen
From now on you can waken with ease
You need never again have a worry or care
I will show you a miracle marvelous rare
Gentlemen, you are about to see something
What rose from the dead on the top of my head

Pirelli’s Miracle Elixir from the musical Sweeney Todd. Lyrics by Stephen Sondeim.

At this point in the musical, Tobias pulls off his cap on his head to reveal thick youthful hair that reaches past his shoulders, however, we quickly find out that Tobias is actually wearing a wig to help sell Pirelli’s elixir and boost sales.

Keeping in mind that this example from the musical is a quite a bit on the exaggerated and laughable side of the scale, but being compliant with Modere product claims is important. What we say about what our products can do for people can be a positive experience but we also must make sure that we speak about these products in the appropriate way.

In the Policies and Procedures (Section 4.6.2) it reminds us that we cannot use claims, such as personal testimonies, of how Modere products can cure, treat, prevent, mitigate, or alleviate diseases. These kinds of claims can be considered medical claims that violate Modere policies and procedures but also can potentially violate federal laws and regulations including the Federal Food, Drug, and Cosmetic Act and the Federal Trade Commission Act.

While some Social Marketers and customers may notice other benefits from using Modere products those benefits may not be typical for every Social Marketer.

An example of unsubstantiated claims would be, “Since I began using the M3 System I have noticed that my fibromyalgia doesn’t flare up like it used to” or “My son has been using the Modere I/D System his acne is almost gone away and his rosacea has cleared up too!”  These kinds of claims could be considered drug or medical claim and are not approved under the product claim policy.

“So what can I say about Modere products?” is probably running through your mind. Each Modere product has substantiated claims Social Marketers can use to describe the beneficial properties of the product.

These claims will enable you and those in your organizational pods to use powerful supporting statements that meet all legal requirements and accurately represent how Modere products promote well-being. These claims are approved and may be used for all of your business advertising and testimonials. (According to Modere’s Policies and Procedures, please continue to submit all Social Marketer produced printed material to the Compliance Department for review.) Please encourage everyone in your organization to use this excellent resource to positively and accurately portray our wonderful Modere products to potential customers and Social Marketers. For current substantiated product claims, please visit the Modere website and under the Products section of each product will list the substantiated claims you can use.

Using one of our unsubstantiated claims above, here is a reworded statement using substantiated Modere product claims:

“My son absolutely loves the Modere I/D! The Defense has helped improve the appearance of redness in his face and the Ecoskin® ingredient has discouraged undesirable bacterial growth.”

One more thing….If other Social Marketers or customers have questions about taking medications and using Modere products at the same time please always refer them to their primary care physician for answers.

Again, we thank you and congratulate you for your dedication within Modere. Working together, we look forward to a prosperous future of health, wealth, and happiness.

If you have additional questions please contact Modere Compliance Department.