If you’ve read the previous 4 articles on making dietary supplement claims you know more than the average health marketer. Hopefully those articles can keep you out of trouble.

Here are links to each in case you missed them

1. Dietary Supplement Claims: What’s Allowed
2. Dietary Supplement Claims: What’s NOT Allowed
3. Dietary Supplement Disclaimers In Plain English
4. The Secret To Making Dietary Supplement Claims (Without Getting Slapped By The FDA or FTC)

In this article, we’ll round out the series by covering exactly how to make a Structure / Function Claim the legal way.

Remember a Structure / Function Claim is one that:

1) Describes the role of a nutrient or dietary ingredient intended to affect normal structure or function in humans.

(2) Characterizes the means by which a nutrient or dietary ingredient acts to maintain such normal structure or function; or

(3) Describes general well-being.

There are 3 ways to properly make a Structure / Function Claim.

Let’s take a look at all three…

Avoid The Giant Leap Pitfall

Remember the video game Pitfall? Where you’d have to swing over a pit on a vine. You want to avoid falling into the pit by making a giant leap.

Here’s what I mean by a giant leap…

Going from one aspect of a dietary supplement, for example a particular ingredient, to the end result of what it does, is a giant leap. You’re leaving out  all of the steps in between.

The FDA sees this as a big No-No. It’s akin to making a drug or disease claim.

Instead, build a bridge and go one step at a time.

An example of that would be briefly…

Step 1 – This dietary supplement has the following patented blend of amino acids.

Step 2 – Explain what an amino acid is.

Step 3 – Explain what amino acids do.

Step 4 – Explain what happens the result on a cellular or molecular level.

Step 5 – Explain the negative side of things. (Potentially from a lack of amino acids or a deficiency in some nutrient for example.)

Step 6 – Leading the prospect over the bridge, let her draw her own conclusion. i.e. Oh, this supplement helps do this.

There may even be many more steps between steps 4 and 6. It all depends on what your particular dietary supplement does.

Going from one step to another is key. Lead them, don’t jump to the end result and thus make a claim. Let the prospects jump to that last conclusion step which leads them to buy.

The second way to properly make a Structure / Function Claim, is too…

Focus, Focus and then Focus Some More With Focus On Top

The key to success in anything is Focus and that includes making proper health claims.

Focus on the “mode” or the “mechanism of action.” 

A “mode of action” describes a change, at the cellular level.

In comparison, a mechanism of action describes such changes at the molecular level and a mode of action happens in the cell.

Sticking to the affect on the body or one of the two types of action keeps you on the safe side.

Focus on one or more specific ingredients.

That is just the ingredients and what the research says about them, not any claims for what they do or might do.

Focus on molecules or cells.

This is done by focusing on the biochemical or molecular level of change that happens in the body.

Just DON’T make any claim about the affect or action of dietary supplement ingredients or molecular cells on any disease.

The third way…

“Setting The Stage” Grouping Your Content

We’ve spoke about this in more detail in The 3 Act Approach to Selling Dietary Supplements which I encourage you to read. But let’s recap it briefly here.

Act 1 – Set The Stage

This act sets up the story. It answers the following questions.

What is the health condition? (i.e. What is the dietary supplement for? Just don’t say that it is for that directly.)

What causes that health condition? How the condition comes about in the body.

What are the affects of it and what does it mean if it goes untreated? (This is the intensification of the problem, for all you direct response copywriters.)

Act 2 – Star The Product

This second act discusses the product and it’s ingredients. It answers the following questions.

What ingredients are in your dietary supplement? List each one out and describe what each one is for, backed up with proof and scientific studies.

What do the ingredients do on a cellular or molecular level to maintain optimal health? Maintaining optimal health is the key here. That’s the way to stay away from a claim.

How do the ingredients do what they do on a cellular or molecular level? Again, specifically to help maintain optimal health.

Act 3 – The Bridge

In this third and last act, you allow the reader to make a leap and come to a conclusion on their own.

You want to lead them to the thought, “By maintaining a particular cell structure, or function of your body they are maintaining a healthy state.”

It is also wise to point out that an “optimal state of health” is mutually exclusive with that of a “diseased or abnormal state of health.”

You’re reinforcing that your claims are NOT about curing, treating, or preventing a disease. Diseases and abnormal states of health are the complete opposite of an “optimal state of health”.

That’s how you use a Structure/Function Claim properly and legally without making a drug claim.

Powerful Dietary Supplement Claims

Making powerful claims and being on the good side of the law, all comes down to two things.

First, not making any form of drug claims whatsoever.

Second, only making Structure / Function Claims in your marketing.

A Structure /  Function Claim is one that describes the role of a nutrient or dietary ingredient intended to affect normal structure or function on the body.

It characterizes how a nutrient or dietary ingredient acts to maintain such normal structure or function, or describes general well-being.

In summary, just remember to stay away from saying or implying that your dietary supplement is treating, curing or preventing conditions, diseases, etc.