Wellness and med spa · FTC
The words a wellness business cannot use.
Four of these 27 phrases are about who works there. “Our doctor”, “physician-led”, “staffed by physician”. If the physician is a medical director who is not on site, the copy says something the reader will take literally.
The rest are the outcome and safety claims the FTC reads as substantiation problems rather than as enthusiasm. Below is the full list the engine runs.
A screening tool, not legal advice. Your compliance officer or counsel has the last word.
7 of the 27
Who actually works here
A medical director and a physician in the room are different things, and the reader cannot tell them apart from a caption. This is the group most likely to be written in good faith and still be wrong.
- doctor recommended
- our doctor
- our physician
- staffed by physician
- staffed by doctor
- physician-led
- physician led
4 of the 27
Proof you have not got
“FDA approved” and “FDA cleared” are different regulatory facts, and a device being cleared does not make a treatment approved. “Clinically proven” needs the trial behind it.
- clinically proven
- scientifically proven
- fda approved
- fda cleared
3 of the 27
Savings you have not substantiated
A savings figure is a comparison claim. It needs a stated basis, not an adjective.
- save you thousands
- save thousands
- saves you thousands
13 of the 27
Outcome and safety promises
Cure, permanence, no side effects, completely safe, fast weight loss, reversed aging. The claims the FTC has brought the most actions about, in the words businesses actually use.
- cure
- cures
- guaranteed results
- permanent results
- no side effects
- lose weight fast
- reverses aging
- pain free forever
- 100% safe
- completely safe
- no downtime
- guarantee
- guaranteed
What every piece has to carry
Refusals are half of it. The engine also checks that these are present, and flags a piece missing any of them:
- The practitioner's credential where a treatment is described
A clean scan is not a compliant piece. Copy with none of the 27 phrases and none of these still fails.
The questions people ask first.
All nine rulebooks, 390 phrases, published in full →
Another trade? Real estate’s 167 → · Mortgage’s 51 →
Can a med spa say it is physician-led?
Only if that describes what a patient will actually encounter. A medical director who is not on site is a different thing from a physician in the room, and the reader cannot tell them apart from a caption.
What is wrong with “FDA approved”?
Usually that it is the wrong fact. Devices are cleared, drugs are approved, and a cleared device does not make a treatment approved. State the specific regulatory status of the specific thing.
Can I say a treatment is clinically proven?
Only with the clinical evidence behind it, for that treatment and that claim. Otherwise it is the substantiation problem the FTC brings the most actions about.
What has to appear on every piece?
The practitioner’s credential, wherever a treatment is described.
Run it on something you already published.
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