Supplement & Cosmetic Claims Checker: FDA & FTC

Check supplement, skincare and beauty product copy for claims that draw FDA warning letters, FTC action and marketplace takedowns. The Supplement & Cosmetic Claims Checker reads product titles, descriptions and bullets and flags disease claims, cosmetic claims that FDA treats as drug claims (regrows hair, boosts collagen, removes cellulite), OTC drug claims (SPF, acne, dandruff), "FDA approved", weight-loss promises, "clinically proven" and other wording that needs proof, and supplement structure/function claims without the required FDA disclaimer. Each finding shows the exact words, a severity, the FDA or FTC source and a note on what to check. Click Start with the prefilled example to see it work.

This is an automated text pre-check, not legal or regulatory advice and not an FDA or FTC decision. A clean result doesn't mean claims are lawful, substantiated or approved; every row carries this disclaimer.

What does Supplement & Cosmetic Claims Checker do?

• ✅ Disease claims: says the product cures, treats, prevents or relieves a disease (cancer, diabetes, arthritis, flu, cold sores, acne and about 50 others), the line between a structure/function claim and a drug claim under 21 CFR 101.93. Pet "treats" and epoxy "cure time" are ignored.
• ✅ Drug-substitute claims: "natural alternative to Xanax", "replaces your statin", "works like Ozempic".
• ✅ Cosmetic-vs-drug claims (cosmetics only): regrows hair, stops hair loss, boosts collagen, repairs cells, removes cellulite, relieves pain. "Reduces the appearance of fine lines" and other look-and-feel wording isn't flagged.
• ✅ OTC drug claims (cosmetics only): SPF and broad spectrum, anti-dandruff, acne treatment, antiperspirant, fluoride. These need an OTC drug label; it's a flag to check, not a ban.
• ✅ FDA wording: "FDA approved" (FDA doesn't approve supplements or cosmetics), "FDA registered" or "FDA certified" facility wording, COVID-19 claims. "FDA-approved color additives" is allowed.
• ✅ Weight-loss claims from the FTC Gut Check list: lose X pounds in Y days, without diet or exercise, melts fat, works overnight.
• ✅ Proof and safety wording: clinically proven, doctor recommended, no side effects, 100% safe, prescription strength, medical grade (medical-grade silicone is ignored), hypoallergenic, non-toxic.
• ✅ Supplement disclaimer check: lists each structure/function claim (supports immune health, promotes restful sleep) and flags supplements that make them without the FDA disclaimer.
• ✅ Output per product: productType (detected or given), riskLevel, issueCount, categoriesFlagged, issues (ruleId, severity, field, quote, context, policyUrl, fixHint), structureFunctionClaims, fdaDisclaimerFound, notes, checkedAt and a disclaimer.

Who is it for?

• Supplement and beauty brands checking product pages, Amazon, Walmart or TikTok Shop listings before launch.
• Agencies, copywriters and marketplace managers who write health and beauty copy for many brands.
• Marketplace and affiliate teams screening third-party product catalogs in bulk.
• Compliance and regulatory teams who want a first-pass triage before legal review.

How to check supplement and cosmetic claims

1. Click Start with the prefilled example (a supplement and a hair serum with risky claims, and a clean moisturizer).
2. Replace the example with your products: title, text (description or claims) and optionally bullets, productType and id. Or paste plain text into Texts only.
3. Or enter a Dataset ID from an Amazon, Walmart, TikTok Shop, Sephora or iHerb scraper, or your catalog export. Use Field map for unusual field names.
4. Set Product type if all items are the same type; otherwise it's detected from the words (title counts double).
5. Turn on Only save products with possible issues for big catalogs; you only pay for saved rows.

Input example

This is the prefilled input:

{
  "products": [
    {
      "id": "EXAMPLE-1",
      "title": "Example Ashwagandha Capsules, 60 Count",
      "text": "Clinically proven to relieve anxiety and supports restful sleep. A natural alternative to Xanax with no side effects. FDA approved formula."
    },
    {
      "id": "EXAMPLE-2",
      "title": "Example Hair Growth Serum, 2 fl oz",
      "text": "Regrows hair in 30 days and boosts collagen production. Hypoallergenic."
    },
    {
      "id": "EXAMPLE-3",
      "title": "Example Daily Face Moisturizer, 1.7 oz",
      "text": "Lightweight cream that hydrates dry skin and reduces the look of fine lines. Fragrance-free; apply morning and night."
    }
  ]
}

Dataset mode:

{"datasetId": "YOUR_DATASET_ID", "fieldMap": {"text": "description", "bullets": "features"}, "productType": "auto", "onlyFlagged": true, "maxItems": 5000}

Output example

Real output from a run of the prefilled input on 2026-10-30 (long finding lists are shortened here; the run returns all of them):

[
  {
    "itemNo": 1,
    "productId": "EXAMPLE-1",
    "url": null,
    "title": "Example Ashwagandha Capsules, 60 Count",
    "productType": "supplement",
    "productTypeSource": "detected",
    "riskLevel": "high",
    "issueCount": 5,
    "categoriesFlagged": [
      "Claims needing proof",
      "Disease & drug claims",
      "FDA wording",
      "Supplement labeling"
    ],
    "issues": [
      {
        "ruleId": "drug_substitute_claim",
        "category": "Disease & drug claims",
        "severity": "high",
        "field": "text",
        "quote": "natural alternative to Xanax",
        "context": "...elieve anxiety and supports restful sleep. A natural alternative to Xanax with no side effects. FDA approved formula.",
        "policyUrl": "https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-F/section-101.93",
        "fixHint": "Presenting a product as a substitute for a drug or therapy ('natural alternative to metformin', 'replaces your medication') is treated as an implied disease claim under 21 CFR 101.93(g)(2). Remove it."
      },
      {
        "ruleId": "fda_approved_claim",
        "category": "FDA wording",
        "severity": "high",
        "field": "text",
        "quote": "FDA approved",
        "context": "...l alternative to Xanax with no side effects. FDA approved formula.",
        "policyUrl": "https://www.fda.gov/consumers/consumer-updates/it-really-fda-approved",
        "fixHint": "FDA doesn't approve dietary supplements, cosmetics (except color additives) or product labels. 'FDA approved' or 'FDA certified' wording on them is false. Remove it."
      },
      {
        "...": "3 more findings: substantiation_claim 'Clinically proven', safety_absolute 'no side effects', fda_disclaimer_missing 'supports restful sleep'"
      }
    ],
    "structureFunctionClaims": [
      "supports restful sleep"
    ],
    "fdaDisclaimerFound": false,
    "notes": [
      "Structure/function claims need substantiation and an FDA notification within 30 days of marketing; this check can't confirm either."
    ],
    "checkedAt": "2026-10-30T11:28:42+00:00",
    "disclaimer": "Automated screening of product text against public FDA and FTC guidance. Flags are..."
  },
  {
    "itemNo": 2,
    "productId": "EXAMPLE-2",
    "url": null,
    "title": "Example Hair Growth Serum, 2 fl oz",
    "productType": "cosmetic",
    "productTypeSource": "detected",
    "riskLevel": "high",
    "issueCount": 3,
    "categoriesFlagged": [
      "Disease & drug claims",
      "Undefined terms"
    ],
    "issues": [
      {
        "ruleId": "cosmetic_drug_claim",
        "category": "Disease & drug claims",
        "severity": "high",
        "field": "text",
        "quote": "Regrows hair",
        "context": "Regrows hair in 30 days and boosts collagen production. H...",
        "policyUrl": "https://www.fda.gov/cosmetics/cosmetics-laws-regulations/it-cosmetic-drug-or-both-or-it-soap",
        "fixHint": "FDA gives these as examples of claims that make a product a drug even when sold as a cosmetic: restoring hair growth, reducing cellulite, treating varicose veins, changing melanin production, regenerating cells. Rephrase to appearance-based wording ('reduces the look of fine lines') or sell it as an approved/OTC drug."
      },
      {
        "ruleId": "cosmetic_drug_claim",
        "category": "Disease & drug claims",
        "severity": "high",
        "field": "text",
        "quote": "boosts collagen production",
        "context": "Regrows hair in 30 days and boosts collagen production. Hypoallergenic.",
        "policyUrl": "https://www.fda.gov/cosmetics/cosmetics-laws-regulations/it-cosmetic-drug-or-both-or-it-soap",
        "fixHint": "FDA gives these as examples of claims that make a product a drug even when sold as a cosmetic: restoring hair growth, reducing cellulite, treating varicose veins, changing melanin production, regenerating cells. Rephrase to appearance-based wording ('reduces the look of fine lines') or sell it as an approved/OTC drug."
      },
      {
        "...": "1 more findings: hypoallergenic_claim 'Hypoallergenic'"
      }
    ],
    "structureFunctionClaims": [],
    "fdaDisclaimerFound": false,
    "notes": [],
    "checkedAt": "2026-10-30T11:28:42+00:00",
    "disclaimer": "Automated screening of product text against public FDA and FTC guidance. Flags are..."
  },
  {
    "itemNo": 3,
    "productId": "EXAMPLE-3",
    "url": null,
    "title": "Example Daily Face Moisturizer, 1.7 oz",
    "productType": "cosmetic",
    "productTypeSource": "detected",
    "riskLevel": "none found",
    "issueCount": 0,
    "categoriesFlagged": [],
    "issues": [],
    "structureFunctionClaims": [],
    "fdaDisclaimerFound": false,
    "notes": [],
    "checkedAt": "2026-10-30T11:28:42+00:00",
    "disclaimer": "Automated screening of product text against public FDA and FTC guidance. Flags are..."
  }
]

How much does it cost to check product claims?

This Actor uses pay-per-event pricing: $0.005 per product saved plus a $0.00005 start fee per run, plus small platform usage paid by you (a few hundredths of a cent for small runs). That's about $0.50 for 100 products and $5 for 1,000 products plus usage. With Only save products with possible issues on, clean products aren't saved or charged. You can set a maximum cost per run in the run options.

Use it through the API, integrations or AI agents

• Run it and get results in one call: https://api.apify.com/v2/acts/ultimatemc~supplement-cosmetic-claims-checker/run-sync-get-dataset-items
• Use it from AI agents through the Apify MCP server: https://mcp.apify.com?tools=ultimatemc/supplement-cosmetic-claims-checker
• Schedule it to recheck your catalog after copy changes, send results with webhooks, or connect it to Make, Zapier, n8n or Google Sheets.
• Chain it after a product scraper by passing the scraper's dataset ID.

How it works

Rules are deterministic text patterns written from public FDA and FTC guidance and federal regulations, checked on 2026-10-29. No AI and no outside calls are used, so the same text always gives the same result. Some rules only apply to some product types: cosmetic-vs-drug and OTC rules run on cosmetics and "other", and the disclaimer check runs on supplements. Severity means: high, wording regulators commonly cite as a drug or disease claim; medium, wording that needs proof, a disclaimer or a specific label; low, a weak signal or a guideline.

Sources:

• 21 CFR 101.93, structure/function and disease claims for supplements
• FDA: Structure/function claims
• FDA: Is it a cosmetic, a drug, or both?
• FDA: Is it really FDA approved?
• FDA: Hypoallergenic cosmetics
• FTC: Health products compliance guidance
• FTC: Gut Check, spotting false weight-loss claims
• 16 CFR 260.10, non-toxic claims (FTC Green Guides)

FAQ

Does a clean result mean my claims are legal?

No. It means none of these text rules matched. Regulators also look at images, packaging, ingredients, the evidence behind claims and overall impression.

Is it AI?

No. It's a fixed rule set, so results are repeatable and explainable, and runs are fast and cheap.

My supplement has the FDA disclaimer. Why are other claims still flagged?

The disclaimer covers structure/function claims only. Disease, drug-substitute, weight-loss and "FDA approved" claims aren't fixed by it.

How is the product type detected?

From keywords such as capsules, gummies, supplement facts (supplement), serum, cream, shampoo (cosmetic) or snack, tea, bar (food), with the title counted double. Set productType per item or for the whole run to override it.

Which countries does it cover?

US FDA and FTC rules. EU, UK, Canada and Australia use different claim rules; many flagged phrases are also risky there, but the sources and limits differ.

Limitations

• Text only: it doesn't read labels, images, videos or ingredient lists.
• It can't check whether a claim is substantiated, whether a structure/function claim was notified to FDA, or whether a product holds an OTC monograph or NDA.
• Implied claims (a before/after photo, a product name like "FluAway") are only caught when the words match a rule.
• English text only. Rules reflect public guidance as of 2026-10-29.
• Product type detection is keyword-based and can be wrong for mixed products; set it explicitly when it matters.

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Found a false positive or a missed phrase? Open an issue on the Issues tab with the product text, and we'll review the rule.