FTC’s Substantiation Bar: Applied Food Sciences (September 2014)


Searching for trends in recent FTC consent orders and related motions

A hint of a trend: Like the 2010 order for Iovate Health Sciences and weight-management claims, the FTC’s stipulated order for permanent injunction for Applied Food Sciences on September 8, 2014, requires the green coffee extract product marketer to have “at least two adequate and well-controlled human clinical tests” for any future weight-management health claims.

FTC Requirement: At least two human studies (for weight-loss claims)


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Jennifer Grebow
Nutritional Outlook magazine jennifer.grebow@ubm.com


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