Dear Charles,
Thank you so much for your cooperation. We appreciate that you’ve already made the changes.
We value the testimonials you’ve provided. However, it is essential to remain within the boundaries of the company’s updated policies and national regulations when sharing such stories online.
To clarify, a disease, drug, or medical claim refers to any statement suggesting that a product can diagnose, treat, cure, heal, or prevent a disease, illness, sickness or any medical condition. Even referencing a symptom of a disease is considered a medical claim.
For example, terms such as "pain," "ache," "headache," "inflammation," or any disease-like symptoms are classified as medical claims.
LifeWave's patches have been categorized as General Wellness Products by the FDA. The FDA allows broader language, which means medical claims, such as the ones we mentioned above, should be avoided. Instead, you can use:
- Supports overall comfort
- Encourages relaxation and ease
- Soothes and revitalizes
- Promotes physical well-being
We understand that LifeWave previously used medical terminology to highlight the benefits of its products. However, in 2023, the company updated its policies to ensure compliance with government regulations.
Moreover, the FDA has clarified that all claims related to stem cells and healing—even those involving natural products—will be considered drug claims. Additionally, the FDA asserts that referencing light’s ability to elevate peptides like GHK-Cu is inappropriate for a General Wellness product.
The best way to determine permissible claims about a LifeWave product is by referring to the Advertising Guidance on Permissible Product Claims. This document provides clear instructions to help you confidently and legally highlight the benefits of LifeWave products online. You may access to the document through this link: Advertising Guidance on Permissible Product Claims 090123.pdf (English); MKT-AD-GUIDE-EU-SP R01.pdf (Spanish)
While we encourage Brand Partners to emphasize the benefits of LifeWave products in verbal communication, any online communication must strictly comply with both national regulations and company updated policies. Product claims are one of the most common violations that may attract regulatory scrutiny. Therefore, we ask all Brand Partners to adhere closely to these guidelines.
Thank you for your understanding and continued cooperation.
If you have any questions or concerns, please reach out to us for further details and assistance.
Best Regards,
DJ G.
LifeWave NAM Compliance Team
13893 Minuteman Drive, Draper, UT 84020
We kindly ask that you review the following policies as they relate to this matter. Sections 4.8.1, 4.8.2, 4.8.3, 4.9.2.2, and 7.5.1.2 of Lifewave's Policies prohibit Brand Partners from making such claims and testimonials.
4.8.1 No Disease Claims: A Brand Partner shall not make any statements that claim LifeWave products will diagnose, treat, cure, prevent, or mitigate disease, nor shall the Brand Partner make any unauthorized representation regarding LifeWave or any LifeWave products. LifeWave Products are not approved for use by persons under the age of 18 unless otherwise directed by a licensed health
care practitioner.
4.8.2 Permitted Product Claims: A Brand Partner may make claims about the Products that are in the Official LifeWave Literature of the country for which it is approved. A Brand Partner shall not make claims about the Product that are not in the Official LifeWave Literature. See Appendix C for permitted and prohibited claims for the country where this Agreement is applicable.
4.8.3 Responsibility for Unapproved Product Claims: A Brand Partner is fully responsible for all its verbal and/ or written statements made regarding the products, services, and Compensation Plan, which are not expressly contained in official Company materials. The Brand Partner agrees to indemnify the Company against any claims, damages, or other expenses, including attorneys’ fees, arising from any representations or actions made by the Brand Partner that are outside the scope of the contract. The provisions of this section survive the termination of the contract.
7.5.1.2 Testimonials: Personal testimonials posted on social media must clearly identify the financial interest of the Brand Partner (see 7.5.1.1). Also, while a Brand Partner’s personal experience may be significant, it may not be typical of the experience of a majority of Brand Partners. Only typical experiences are allowed. Therefore, the Brand Partner’s testimonial must limit its claims to those allowed in Appendix C1.
4.9.2.2 Income & Lifestyle Claims: No express or implied income claims or lifestyle claims may be made to prospective or current Brand Partners, nor may Brand Partners use their incomes as indications of the success assured to others.
To guide you in creating compliant income/lifestyle content, we encourage you to review page 44 and 45 of the Company Policies and Procedures. This document provides clear instructions to help you confidently and legally highlight the benefits of LifeWave products online. You may reach it at the following link: PnP_US_EN_16Apr2025
Further guidance on approved product claims can be found in LifeWave’s “Advertising Guidance on Permissible Product Claims” document, which can be found here:
