This is the first thing to notice about the marketing for this product, and it is easy to miss because the two documents arrive in the same envelope.
On the bottle, under the wordmark, three phrases with three small icons: healthy nerve function†, the neurological system† and blood flow & circulation†. Each carries a dagger. The dagger resolves, on the back of the same label, to the standard disclaimer: “These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.” That is the correct construction, and a great many packs this desk has read get it wrong.
On the guarantee panel supplied with it, three different promises: Support Healthy Nerve Function. Give your nerves the nutrients they rely on every day. · Promote Everyday Comfort. Support healthy and comfortable hands and feet. · Stay Active and Independent. Support the mobility to keep doing what you love.
Those three carry no dagger and no disclaimer where we were shown them, and the third of them is not a structure-function claim at all. Stay active and independent is a claim about a life. Keep doing what you love is a claim about a life. Neither describes a structure or a function of the body, which is what the category of claim is named for.
We are not saying anyone broke a rule — we have seen one panel, not the page it sits on, and the disclaimer may well appear elsewhere on it. We are saying that the bottle is careful and the marketing is less careful, and that the gap between the two is where a buyer's expectations get set.