A few days ago the natural remedy community received a firm smack on the hand by the FDA when they sent warning letters to doTERRA, Young Living, and Natural Solutions Foundation. The common thread among these three warnings was a claim regarding the Ebola virus. Some essential oil enthusiasts claim to be censored and feel their freedom of speech has been violated. Is this really a case of censorship?
There are two agencies which hold the responsibility of making sure all American companies are held accountable for how they label and market their products, the FDA and the FTC. In addition to this, the Ebola virus has a patent, which means no one can make a claim about Ebola unless they want to make waves with the inventors and owners.
Two of these three companies are Multi-level marketing companies with independent reps who market the products. While doTERRA’s corporate publications are in compliance, some independent reps have blogs that weren’t. doTERRA had already been working with those bloggers to bring their sites into compliance, as all essential oil advocates should do as well.
“Yesterday we received an advisory letter from the FDA. It addressed the way a select few Wellness Advocates have been marketing essential oils online. Because dōTERRA products are natural products and are not registered with the FDA as drugs, we are restricted on the health claims that can be made for marketing purposes. We recognize essential oils have profound health benefits, but it is important we not make claims that would position our products as drugs. For example, recommending an essential oil to cure a particular disease would be considered a drug claim. dōTERRA does not claim our products cure or treat the Ebola virus or any other disease.
dōTERRA works closely with you, our Wellness Advocates, to ensure marketing materials are compliant. Please understand the FDA is not suggesting dōTERRA is making claims in our marketing materials or labeling. Rather, they are encouraging us to make Wellness Advocates aware they should not make drug claims when marketing dōTERRA products.
In our normal course of compliance auditing practices, we had already identified and resolved some of the online marketing materials referenced in the FDA letter.”
See the Warning letter to doTERRA here.
Young Living also has reps with social media platforms that are not in compliance, as specified in the warning letters. See the Warning Letter to Young Living here.
From what I have observed in the blogosphere, this seems to be a communication gap for bloggers and the FDA letters are there to serve us as well as our consumers. I don’t think these bloggers intended to deceive their readers or consumers. Many times it’s a thin rope to walk as we express how beneficial essential oils are for our wellness, coupled with personal testimonies of wholeness. This is an area of marketing that we all could use some brushing up on.
Many bloggers don’t understand the verbiage limitations for home remedies and supplements. Between the FDA and the FTC, their jobs are to make sure the marketing of products fit their intended usage.
Essential oils are not classified as drugs; therefore they should not be marketed as such. If we use verbiage traditionally used for treating diseases then that would make essential oils a drug. If essential oils were a drug, then we would not have the freedom to purchase them without a prescription. It is in the best interest of us consumers, to keep essential oils free from being held hostage by pharmaceutical companies in hopes that a physician decides to accept bribes to prescribe them.
I’m not sure this is a case of censorship as much as it is a reminder to market products based on their legal classification. When we represent products that we profit from, we have to be extra careful in how we describe them. If we weren’t in a position to profit, then our testimonials wouldn’t have the same guidelines issued to us by both the FDA and FTC.
Are essential oils unapproved drugs, as the FDA letters seem to indicate?
Technically, yes.
Essentially, no.
According to the FDA, if you sell and market a product intended to cure, mitigate, treat, or prevent a disease then it’s a drug. An unapproved drug automatically becomes an “illegal drug”. However, essential oils are not really drugs, they are botanicals under the listing of supplements. Essential oils are classified under foods as a dietary supplement.
When a blogger misrepresents an essential oil as a cure for a disease, then that blogger portrays essential oils as a drug. When this happens the FDA is required to step in and request a correction. So when you see the FDA state that oregano, peppermint, or vetiver essential oils are unapproved drugs, you need to see it in context of the manner in which the blogger explained those essential oils along with the reason the FDA issues the warnings.
When essential oils are described as remedies for diseases, then they are portrayed as a drug (without approval). It doesn’t necessarily make an essential oil a drug (or even an illegal drug). Though, the FDA says it does make it an illegal drug. Go figure.
Now, if I choose to take 3 drops of oregano oil (diluted of course) to ease my flu symptoms, I’m essentially taking an “illegal drug”. Do you see how convoluted these laws can become? If I choose to take oregano essential oil internally for the flu, that should be my personal choice and I should have the freedom to do so. It’s a matter of understanding context and having a clearer understanding of the classifications of these products. Perhaps the FDA can brush up on context and our Constitutional freedom. In the mean time, I won’t advertise oregano essential oil as a product that combats the flu.
Essential oils are not intended to cure, mitigate, treat, or prevent a disease.
Essential oils are supplements intended to support our body’s functions.
When our bodies are at optimal health, then the body naturally combats invaders that intend to harm us.
According to the FDA, a drug is:
“intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease in man or other animals” source
Furthermore, they describe a supplement as:
A “dietary ingredient” may be one, or any combination, of the following substances:
• a vitamin
• a mineral
• an herb or other botanical
• an amino acid
• a dietary substance for use by people to supplement the diet by increasing the total dietary intake
• a concentrate, metabolite, constituent, or extract
Dietary supplements may be found in many forms such as tablets, capsules, softgels, gelcaps, liquids, or powders. Some dietary supplements can help ensure that you get an adequate dietary intake of essential nutrients; others may help you reduce your risk of disease.
source
The FDA does not approve dietary supplements. source
The FDA recently updated one of their pages just the other day (prior to these letters being issued), in regards to aromatherapy and essential oils. source
One thing they included, which seems like a grey area to me, is this;
“If a product is intended for a therapeutic use, such as treating or preventing disease, or to affect the structure or function of the body, it’s a drug. For example, claims that a product will relieve colic, ease pain, relax muscles, treat depression or anxiety, or help you sleep are drug claims.”
The part that concerns me here is ‘ease pain, relax muscles’ and ‘help you sleep’. This is where laws become a tangled mess and here’s why. Ice can ease pain and a hot bath can relax muscles. Are ice and hot water a drug then? A glass of warm milk helps me sleep; does that mean milk is a drug? If I use chamomile tea bags on my sunburn does that mean it’s a drug? Surely, the FDA won’t force milk, ice, hot water, and tea into a drug classification requiring a physician’s prescription before we can get our hands on them.
While the FDA has a huge job to do in order to classify products and police blogs, Pinterest, and Twitter about what we use for home remedies, their legal jargon can become quite extreme.
So, what’s a blogger to do? Well, we need to use caution in how we describe home remedies, essential oils, milk, ice, or tea for that matter. Don’t portray these items as drugs that cure, treat, mitigate, or prevent diseases. If you use tea bags on your sunburn and want to talk about it, be sure you’re not selling the tea by directing people to your Amazon affiliate links. If you use warm milk to help you sleep, don’t link to an affiliate that sells milk.
While companies and their marketing reps are limited in what they say, consumers should have the freedom to say whatever they want.
In the meantime, check out the gazillion studies published on the government’s PubMed site that prove the amazing benefits of essential oils.
Did you know there was a Bill introduced to Congress that would support our FREEDOM to teach the truth about the scientific facts about supplements (including essential oils)? Unfortunately, the Bill died. WE the People need to get it back in Congress!
Read more about what YOU can do to protect this freedom!
*Disclaimer: As an Wellness Advocate I provide my personal opinion and experiences with essential oils, and am not endorsed by dōTERRA Corporate. None of what I testify of has been evaluated by the FDA, nor is it intended to diagnose, treat, cure, or prevent any disease. I am not a registered medical professional and I encourage you to discuss your health concerns with your own doctor. I simply share resources and tools to raise consumer awareness. This post may contain affiliate links. Read my full disclaimer here.
I am a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to Amazon.com
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