Hey there copywriter,
How do you feel when you finish working on a big project? You know what I mean, right?
I’m talking about the uplifting feeling you get when you can finally close internet tabs you’ve had open for days.
The accomplishment you feel as you hit save on the final copy draft. And the nervous excitement that hits moments after sending the copy to your client for approval.
Nothing beats that feeling.
BUT what if instead of approval you received this spine-straightening message from your client:
“Your copy violates Federal Trade Commission (FTC) guidelines and puts the entire project in jeopardy. Call me ASAP.”
Suddenly your good vibes are replaced with feelings of dread. You spent hours working on that copy and now you’ll have to start all over again.
Or worse, you may have lost a client…
If you’re new to health copywriting you may be wondering what FTC guidelines are. In 1980 the FTC created guidelines for companies that advertise dietary supplements.
The guide got a facelift in 2022 and now the guidance extends to all health related products. These rules were written to protect consumers from dangerous products and useless duds.
When a company breaks one of these rules they’ll receive a warning letter from the FTC. If the misleading advertising continues the company will be fined up to $46,517 per violation. [1]
So, if you write health copy or you want to start, you need to understand FTC guidelines and follow them.
Do you want to learn how to write health copy that follows FTC guidelines AND puts more money in your client’s pocket?
Keep reading to learn 11 rules for mastering health copywriting.
Every claim your health copy makes needs evidence to support it. There are two types of claims:
Express claims are claims you directly make about the benefits of your product. You need evidence to support any express claims in your health copy.
For example, if you say 90% of urologists use your product to maintain a healthy prostate. Then you need evidence to show they use it and that it improves prostate health.
Implied claims are trickier to find… They’re like clues in your health copy that imply a benefit.
Let’s say you’re writing health copy for a joint supplement called Arthricure. In the ad there is a before picture of an elderly woman using a cane.
A few pages later an after picture shows the woman dancing with her husband.
The pictures in this ad imply that Arthricure helps treat arthritis. So, you need evidence to back the claim up.
Always review your content, pictures and even the product name to find implied claims. Once you find them, you can either weed them out of your copy or find evidence to back them up.
What sort of evidence counts?
Well the FTC says “competent and reliable scientific evidence is needed”. [2] So tests, analyses, research studies and other relevant evidence will work.
Make sure the evidence you choose was completed and reviewed by qualified professionals.And always back up your claims with quality evidence.
If your claims have qualifiers or caveats you need to include them in your health copy too.
Any qualifying information needs to be included in your health copy. Qualifying information is any info that could affect the weight of your claim.
Here’s an example:
You’re writing copy for a weight loss supplement and you claim “This pill can help you lose over 15 pounds in just 8 weeks!”
The claim was based on a study that showed people who used the active ingredient in the pill lost an average of 15 pounds over 8 weeks.
But what if those people also followed a strict diet and exercise routine during the study? You have to include that information along with the claim in your copy.
Why? Because some consumers will think taking the pill alone will bring those results.
Qualifying information is also important whenever you make product safety claims. Your advertisement should mention any safety risks your product has.
This gives consumers the chance to make an informed decision about the product.
Think about qualifying information like the disclosures you hear on commercials for medications. At the end of those ads every side effect from itchy scalp to smelly feet is quickly mentioned.
Include disclosures in your health copy so consumers don’t get the wrong idea about your product. Speaking of disclosures, it sure is easy for prospects to miss them if they’re in small print or hard to find.
Disclosures give customers more information about the product you’re advertising.
Disclosures need to be clear and easy to understand. If prospects can’t find or understand the disclosure, your health copy could mislead them.
So be sure to follow these tips when making disclosures in your health copy:
Disclosures should be in plain, easy-to-understand language. Using medical jargon or complex words is a bad idea (those words don’t belong in your health copy anyway).
Avoid using small type or hard to read fonts when writing disclosures. Instead write disclosures with a large enough type size in a font that’s easy to read.
Disclosure location matters too. A fine print disclosure at the bottom of a print ad or one that’s easily missed on an internet page won’t cut it. Place disclosures near claims so consumers can find them.
Another FTC rule to follow in your health copy is showing proof for statements of support.
Any supporting statements about your product that make generalizations about experts in the industry need proof.
Here are a two examples of industry support:
“Experts believe…”
“Scientists now agree…”
If you make claims like this in your copy you need evidence to show industry consensus (agreement) supports them.
The FTC checks into these statements by consulting with experts in the field.
So if your health copy says: “Medical doctors now agree THIS plant can cure cancer.” Consensus in the medical community about the plant is needed.
We’ve talked a lot about evidence. You may be wondering how much evidence is enough to back-up your claims? And are some types of evidence stronger than others?
There isn’t a set number of studies needed to back-up your claims. The FTC values quality over quantity so choose high quality studies to back claims up.
High quality, randomized, controlled human clinical trials are the most reliable study you can use. If there aren’t studies like this for your product, other types of evidence may be allowed.
Here’s an example:
A company wants to advertise a vessel strengthening supplement. There have been two large scale, long-term epidemiological studies on the product.
These studies show an association between vessel health and use of the supplement. A clinical trial would be very hard to complete in this situation.
In this case you still need to meet two requirements:
What if the product you’re selling hasn’t made it to human clinical trials yet? Animal and in vitro studies can be used if they’re accepted in your industry.
Now that you know which studies are best, how do you go about choosing high quality evidence?
By now you know you can’t use just any study to back up your claims. High quality evidence will make your health copy better.
What makes a study high quality? Well, the FTC pays attention to how the study was designed and implemented along with the results.
Here are a few examples of rock solid studies:
A few things to remember when choosing studies for your health copy:
Speaking of high quality evidence, what if one study supports your claim but others don’t?
Can you use the first study to back-up your claim even if more evidence tells a different story?
All the evidence matters. You need to review all the evidence relating to your claimed benefit (not just the evidence in your favor).
The studies you use to back-up your claims should be consistent with the majority of evidence.
If the evidence you rely on is different than other reliable sources then you’ll need to think about a few things:
Your answers to those questions will show you if the contrary evidence is stronger. If it is then you’ll need to find other evidence to back-up your claim or remove the claim from your health copy.
What if you can’t find high quality studies to back up your express or implied claims? One way around this is by basing claims on traditional use.
You can base your claims on traditional use of a product. But remember, claims based on traditional use still need evidence to back them up.
If you can’t find evidence to support the claim then clearly state the claim is based on history of use of the product.
Things to avoid:
Traditional use claims should show how much the ingredient has been used. So if the ingredient has been used by millions of people for years or decades your claim should be pretty solid.
You may wonder why some products need scientific evidence to back them up and others don’t. The FTC bases this criteria on how the public views the product. So it depends on the product you’re writing about.
If consumers expect scientific studies to back up claims for your product you will need them.
Also, if your claim could put people in danger you need high quality evidence to support it.
For example, an implied claim like:“Thanks to Nutrishield I canceled all my doctor’s appointments” would need high quality evidence to back it up.
Now that you know how to find strong evidence to back up your claims we should talk about testimonials.
I’m sure you’re itching to include a few fire testimonials in your health copy. But you should think twice before choosing which testimonials to use.
Testimonials still need scientific evidence to back them up.
Think back to what you learned about implied claims. If you publish a testimonial that reads:
“I suffered from gerd for years. Nothing I tried worked and my prescription meds caused more harm than good. Now that I’ve found GoEasy my acid relux is completely gone!”
You still need strong evidence to back up the claim. Testimonials alone aren’t enough to show that the active ingredients in your product can cure acid reflux.
Another thing to look out for when using testimonials in your health copy is extraordinary results. If you include a testimonial from someone who lost 8 lbs over 8 weeks using a diet pill you need to show that the results are typical for most users.
If they aren’t, choose a different testimonial or include a clear disclosure about what most users experience.
Be specific in your disclosure. Avoid vague messages like: “Results may vary”. And make sure to place the disclosure near the testimonial so customers can find it easily.
DSHEA is The Dietary Supplement Health and Education Act of 1994. Any nutritional statements you make about a dietary supplement need to include a 2 part DSHEA disclaimer.
Including this disclaimer shows consumers your product has not been reviewed by the FDA. It should say:
Note: Including a DSHEA disclosure doesn’t mean you can make misleading claims. You’ll still need to back your claims up with evidence.
Here’s an example of the wrong way to use DSHEA disclaimers:
“You’re writing health copy for a health supplement and claim it can cure diabetes. Your client doesn’t have any evidence to back the claim up. Instead she places a DSHEA disclaimer near the claim.”
Since there isn’t any evidence to back the claim up this is a misleading ad. You should also avoid stating or implying FDA approval for a product simply because a DSHEA disclaimer was used.
The last type of evidence you should know how to use in your health copy is third party literature.
What is third party literature and why should you use it in your health copy?
Examples of third party literature:
Third party literature can add credibility to the claims you make in your health copy. But remember, claims about the ingredient or product in third party literature still need proof.
What if you find a book that supports use of the ingredient in your supplement?
You quote the title of the book and include parts of it in your health copy. You’ll need to back up any claims the book makes about the ingredient (even those you don’t mention in your health copy).
Third party literature is exempted from DSHEA dietary labeling requirements if:
The FTC doesn’t control the content of published books or articles. But it does have laws against using the materials to mislead people in your health copy. So make sure any third party sources you use follow the guidelines above.
There you have it! Now you know 11 rules for mastering health copywriting that protects your client from violating FTC guidelines.
But if you’re new to copywriting this is only the beginning of what you’ll need to know to get really good at it.
Want more helpful copywriting tips you can use to quit your day job?
Sign up for my mailing list below to get marketing insights, productivity hacks and copywriting tips sent to your email weekly.
Until next time.
Yours, for better health copywriting,
Brandon Davis
References: