FTC to Host September Workshop in Washington, DC, to Examine Advertising for Over-the-Counter Homeopathic Products #00481

Submission Number:
Lorri Anderson
Initiative Name:
FTC to Host September Workshop in Washington, DC, to Examine Advertising for Over-the-Counter Homeopathic Products
As a homeopathic practitioner whose first career was in advertising and who has spent more than a decade on the retail floor of a dispensing, compounding and natural pharmacy, I am fully qualified to speak on the state of advertising for homeopathic products. The genuinely homeopathic manufacturers trading in the United States are doing an effective and informative job with their advertising messages and materials. I have seen hundreds (possibly thousands)of customers use manufacturer-provided materials to learn something of different products and make informed purchase decisions. I have also had the opportunity to hear follow up from many of those consumers, and the vast majority have been satisfied that they were able to choose a safe and effective product for their needs. Success was not 100%, of course; but even many of those who found their product selections ineffective or only partially-effective were still pleased with an aspect of their experience. Many felt reassured about product safety; some commented on learning something; others felt they had found a reliable brand; most would try homeopathy again. As a homeopath, I might have made different product choices for some of them; but I have studied extensively and practiced for many years. Overall, I have found the consumers' abilities to choose among the wide array of products unexpectedly accurate. Boiron, Hyland, & Heel (no longer selling in the United States) have all provided high quality advertising, in-store & electronic communications - as have others. A single good example is available at http://shop.boironusa.com/mf/; many more are no doubt available to you. The legitimate homeopathic manufacturers should be encouraged to continue in the manner they have established. Unfortunately, there is also a group of products and manufacturers who co-opt the word "homeopathic" for products which have no claim to homeopathic production, process, use, record of safety or effect. Some of these products are nutritional, herbal, etc. and may (or may not) have a legitimate contribution to make; but they have not - and can not - earned a place in homeopathy. Since these products are not actually homeopathic, they fall outside of my credentialed expertise. But I believe the products in this group which have a genuine contribution to make to health and wellness should be permitted to continue in the marketplace, but only after they have cleaned up their messages to remove the inaccurate claim to being homeopathic. And those lesser offerings without a contribution must certainly be prohibited from claiming to be homeopathic; likely they have additional infractions, as well. To summarize, the actual homeopathic products in the marketplace are being supported by valuable advertising messages and materials which are serving consumers well. These companies should be encouraged to continue as established. However, companies selling products which claim to be "homeopathic" but do not meet the criteria of the discipline need to be prohibited from using the term. Since "homeopathy" does not have a trademark or rigorous trademark defense department such as Kleenex disposable tissues, Weber grills, or Walt Disney anything, perhaps this is an area where the FTC could be of service. Thank you. Sincerely, Lorri Anderson, CCH