How the FDA Warning Letter to Young Living Essential Oils should influence Influencer Marketing
Written by: Jackie Torfin, Partner
A warning letter published on July 19th by the FDA to Young Living Essential Oils names not only the company but also individual consultants within its multi-level marketing organization (find it below). The FDA used specific statements from each individual's social media accounts (usually Instagram) to make its case. In our research, this is the first time individual contracted agents have been named in a warning letter. This evolution in strategy from the FDA sends a clear message to sales agents as well as people operating in this gray area of "influencer marketing" that their public activities may result in formal regulatory actions and could lead to personal liability.
This was at least the second time Young Living has encountered issues with the FDA, receiving another warning from the FDA in 2014. Since that time, there have been several OTC drugs manufactured/distributed by Young Living registered with the FDA (e.g. Salicylic acid in their Acne Treatment). In addition, there is an interesting and informative FAQ (find it below) detailed with specific guidance on how to avoid making false claims about the products being sold. It didn't work.
QRx Partners discuss this interesting case with an expert Marketing executive who has training and exposure to FTC regulations (see below). The game has changed with the entrance of the FDA in this space. We talk about why this could be problematic for other influencers, and micro-influencers and give a few tips on how they might try to avoid being in this same situation. Enjoy the discussion!
If all this seems daunting, QRx Partners can guide and support you in your quest to steer clear of FDA issues. Contact us at Contact@QRxPartners.com or 833-779-7278.
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