The National Advertising Division (NAD) of the Advertising Self-Regulatory Council (ASRC) has recommended that New Nordic US, Inc. either modify or discontinue certain claims for its Hair Volume® dietary supplement on the ground that they imply an ability to reverse balding, including geneticpattern baldness, in women. Among the purportedly questionable product claims that NAD reviewed were (i) “Thousands of people have already experienced the benefits of Hair Volume, which has made it the world’s leading hair tablet with natural apple hair growth factor”; and (ii) “Strengthens your hair. With hair growth factors and minerals for hair follicles, skin and nails.”

The company also apparently promoted its product with a testimonial: “I started taking the new Hair Volume tablets and the transformation was incredible. My hair appeared with more thickness, more life. It feels and looks more vibrant and healthier . . . Even my nails are stronger. All this with one tablet a day. This is proof that with the right nutrients you don’t have to accept your family fate.” NAD, part of an industry self-regulatory system administered by the Council of Better Business Bureaus, recommended that the company discontinue the claims at issue, as well as the testimonial. The company agreed to accept the recommendation, although it stated, “we felt we had some substantiation from the clinical studies of our ingredients.” See ASRC News Release, July 25, 2013.