The FTC issued a policy statement on November 15, 2016 regarding the marketing of homeopathic “drugs” to consumers. The statement was the culmination of research and analysis incorporating information gathered from a workshop last year where various parties – homeopathy advocates, organizations and producers along with science-based medicine advocates – provided comments.
The policy changes the marketing rules for homeopathic products in that “[e]fficacy and safety claims for homeopathic drugs are held to the same standards as similar claims for non-homeopathic drugs.”
That is, companies must have competent and reliable scientific evidence for health-related claims, including claims that a product can treat specific conditions. The statement describes the type of scientific evidence that the Commission requires of companies making such claims for their products.
Advertisers are expected to have “competent and reliable scientific evidence,” backing up their claims which is defined as “tests, analyses, research, or studies that have been conducted and evaluated in an objective manner by qualified persons and [that] are generally accepted in the profession to yield accurate and reliable results.” With regards to health claims, that means well-designed human clinical testing.
The disclaimers needed if they do not have those positive results must “effectively” communicate to consumers that:
(1) there is no scientific evidence that the product works and (2) the product’s claims are based only on theories of homeopathy from the 1700s that are not accepted by most modern medical experts.
In order to show their disclaimers are clear to consumers, they have to demonstrate they have tested them and determine that people actually understand what they are buying.
Marketers are advised to develop extrinsic evidence, such as consumer surveys, to determine the net impressions communicated by their marketing materials.
There is room for homeopathic producers and marketers to slip through some of these requirements, I’m sure they are working on that right now, but the ruling was a positive step by the FTC to explain the problems with homeopathy. If consumers wish to buy placebos produced by a method modern medicine doesn’t consider valid, they still can, but now they are aware there is no reasonable scientific evidence to back it up.
- Enforcement Policy Statement on Marketing Claims for OTC Homeopathic Drugs [PDF]
- Homeopathic Medicine and Advertising Workshop report [PDF]
- FTC Homeopathy Win « Science-Based Medicine
- A rare win for science: The FTC issues its enforcement policy on homeopathic remedies
- Homeopathic Medicines Will Carry Labels Saying They’re Unscientific
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