Tell the FTC to Revise Its Consent Decree for an Omega-3 Memory Supplement!

The Federal Trade Commission has charged a supplement company with false advertising because they have been saying their Omega-3 product BrainStrong Adult was “clinically shown to improve memory [and] help protect against normal cognitive decline as we age.” They had a double-blind random-controlled trial (RCT) to substantiate their statements. The FTC said the single RCT was insufficient and now a second RCT would be required.

The double RCT standard is used under the Food Drug and Cosmetic Act (FD&C) to establish disease claims for drugs. This process is overseen not by the FTC, but by the FDA. And, importantly, there is no such requirement for health claims for supplements. For the FTC to insist that RCTs are now the standard for health claims, by law the agency would at the very least have to undergo a formal, rulemaking procedure.

The consent decree, if accepted, broadens the scope of when RCTs are required. This will deter other supplement companies from investing in RCTs, which will limit the number and kind of claims that supplement companies will be able to safely make.

On July 9, JUST ONE DAY FROM NOW, the FTC must consider comments and decide whether to sign or withdraw the consent decree. Please contact the agency TODAY and demand that they revise the proposed consent decree!

Please personalize your message if you have the time!


  • Federal Trade Commission


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