Your website is legally part of your product’s “labeling” which means an unsupported claim on a product page, blog post, or linked social account can trigger the same FDA enforcement as a defective physical label. Shehadeh Giannamore, PLLC performs FDA website reviews for food, supplement, cosmetic, and OTC drug companies, checking every page including linked sites for claims that would draw FDA scrutiny.
| Who needs this | Any company selling or marketing an FDA-regulated product online |
| What’s reviewed | Product pages, blog content, testimonials, linked social accounts, embedded ads |
| Legal basis | FD&C Act “labeling” definition (21 U.S.C. § 321(m)); misbranding provisions (§§ 343, 352, 362) |
| What’s at stake | Warning letters (public, and often the top Google result for your brand), FTC overlap for deceptive advertising |
| Related page | See FDA Label Reviews and Marketing Reviews for how website claims tie into your overall labeling risk |
What Is an FDA Website Review?
An FDA website review checks every consumer-facing page of your site and everything it links to against the same claims-based rules that apply to a physical product label. The FDA decides how strictly to regulate a product based on its intended use, and intended use is established by what you say about the product, wherever you say it. A website review identifies exactly which statements are safe, which are risky, and which need to come down.
Why Your Website Counts as FDA “Labeling”
Courts and the FDA have long treated a product’s “labeling” as including any written, printed, or graphic material that accompanies the product not just what’s printed on the physical container. That definition has been applied to websites, social media, and even hyperlinked third-party content for years. Practically, that means a customer testimonial you republish, a blog post about your ingredient’s benefits, or a claim buried in an Instagram caption can all be treated as labeling for enforcement purposes, regardless of what your printed label says.
What We Review on Your Website
- Product and category pages for structure/function, health, nutrient content, and disease-claim issues
- Blog and educational content that references your product’s benefits or ingredient effects
- Customer testimonials and reviews displayed on-site, which the FDA treats as claims made by the company if adopted or amplified
- Linked social media accounts and influencer content that references the product
- Embedded ads and landing pages, including any claims that differ from what’s on the physical label
Common Website Compliance Mistakes
- A blog post making a disease claim (“relieves arthritis pain”) for a product marketed as a supplement
- Testimonials on a product page containing disease claims the company wouldn’t make itself
- Website copy that goes further than the physical label a common gap once a marketing team updates a site without legal review
- Linked influencer or affiliate content making claims the brand never approved but is still responsible for
Our FDA Website Review Process
- Submit your site URL, and identification of any linked social accounts or affiliate pages you want included
- Page-by-page claims review against the statute and regulations for your product category
- Written findings report flagging each page and statement as compliant, at-risk, or noncompliant
- Compliant alternative language for anything flagged
- Final sign-off before changes go live, plus ongoing review as you add new pages or campaigns
Not sure if your current label or marketing would survive an FDA review? Get an attorney's eyes on it before you find out the hard way.
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- Is my website actually regulated by the FDA?
- Yes. The FDA and courts treat a product’s website as part of its “labeling,” meaning claims made on your site are evaluated under the same misbranding rules as your physical product label.
- Do customer testimonials count as claims I’m responsible for?
- Generally yes, if you select, display, or amplify them. A testimonial making a disease claim on your product page can be treated as a claim made by your company, even though a customer wrote the original words.
- What if my website makes a claim my physical label doesn’t?
- That’s still a problem and a common one. FDA enforcement doesn’t require the claim to appear on the physical label; a claim anywhere in your labeling, including your website, is enough to trigger scrutiny.
- Does an FDA website review cover my social media accounts too?
- It can and should — accounts you control or that are prominently linked from your site are typically reviewed alongside the website itself, since the same claims exposure applies.
- How is a website review different from a full label and marketing review?
- A website review is a focused subset of a full FDA label and marketing review, specifically covering online content; many clients combine both to cover every channel where claims appear.
Talk to an FDA Website Review Attorney
Before your marketing team publishes new website content, get it checked against FDA regulations. Contact Shehadeh Giannamore, PLLC for a consultation.
Toll-free: (866) 785-0873
Direct: (305) 507-9843
Email: contact@giannamore-law.com
Schedule a ConsultationThis page is for general informational purposes only and does not constitute legal advice or create an attorney-client relationship.