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How to Correctly Use Structure-Function Claims

In the wellness industry, the right claim can make or break a product. But saying the wrong thing, like hinting that your supplement treats disease, can land you in hot water. That’s where structure-function claims come in. These claims let brands highlight real product benefits without crossing regulatory lines. But they must be scientifically sound, legally compliant, and not misleading. Here’s what you need to know to use them strategically and safely.


skincare product claims

What Are Structure-Function Claims?


Structure-function claims explain how a product supports the normal structure or function of the body, without mentioning disease prevention, treatment, or cure.


Examples include:


  • “Vitamin D supports bone health”

  • “Probiotics help maintain digestive balance”

  • “Biotin promotes healthy hair and nails”


They’re especially common in supplements, functional foods, skincare, and pet wellness, industries where consumers want benefits but the products aren’t classified as drugs.


Why They Matter for Brands


Done right, structure-function claims can:


  • Help your product stand out in a crowded market

  • Communicate clear, benefit-driven messaging

  • Build consumer trust, especially if supported by clinical trials


They give you a way to talk about your product’s positive effects without triggering drug-level scrutiny.


Structure-Function Claims Require Substantiation


This isn’t just a marketing exercise, claims must be backed by scientific evidence. That’s why many brands turn to affordable clinical trials to prove their claims.


A few real-world examples:


  • A hydration serum clinically shown to increase skin moisture can claim to “improve skin hydration.”

  • A superfood powder tested for gut microbiome support can claim it “supports digestive health.”


Even small-scale, well-designed trials conducted by third-party CROs (Contract Research Organizations) can provide the credible data you need.


What They Are Not: Disease Claims


A structure-function claim cannot suggest your product treats, cures, or prevents any disease.


Compare:


  • Good: “Supports cardiovascular health"

  • Bad:  “Prevents heart disease”


Crossing this line, even unintentionally, can reclassify your product in regulators' eyes, something most brands want to avoid.


FTC Oversight and the Risk of Noncompliance


The Federal Trade Commission (FTC) actively monitors structure-function claims to ensure consumers aren’t misled. If you make a claim, you need “competent and reliable scientific evidence” to back it up.


To stay compliant:


  • Ensure all claims are grounded in published research or proprietary clinical trials

  • Avoid testimonial overreach (e.g., customer stories implying disease treatment)

  • Include disclaimers like: “This statement has not been evaluated by the FDA…”


Tips for Using Structure-Function Claims Correctly


  1. Use precise language, no vague or exaggerated claims.

  2. Invest in clinical trials, even if they're small and product-specific.

  3. Consult a regulatory expert or CRO before launching a campaign.

  4. Include appropriate disclaimers on packaging and marketing materials.

  5. Keep documentation, if the FTC comes knocking, you’ll need it.


How to Make Structure-Function Claims Work for You


Structure-function claims aren’t just about legal safety, they’re about building credibility and trust. By supporting your claims with solid clinical evidence, you not only stay compliant, you also strengthen your brand.


Whether you're launching a collagen supplement, a plant-based protein, or a pet joint support chew, structure-function claims can be a powerful part of your strategy, if you do them right.


Are you looking to make bold and factual marketing claims for your products? Get in touch and contact us today to learn more about how Citruslabs can help you in your marketing journey!

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