Health Claim Review for Paid Media, US and Canada

The claim that gets an account restricted is rarely the headline. Across the review sets I have run, most of my rewrite dispositions land on copy nobody thought of as a claim: a testimonial pull quote, a chart axis label, the alt text on a before-and-after image, a bullet inside an FAQ accordion. I work claim by claim rather than asset by asset, and a paid-media launch set typically breaks into 120 to 200 discrete claims once the landing pages and the post-click funnel are counted. How the file is built: Every claim returns as a row. Verbatim text. Where it lives, down to creative ID, URL and DOM path, or video timestamp. What kind of claim it is under the framework that governs it: structure and function, disease, comparative, establishment, safety. The substantiation you already hold. Then one of four dispositions. Run. Reword, with the replacement line written out and ready to paste. Substantiate, with the specific study design or third-party test that would carry the claim as written. Drop. The reword column is the one clients actually use. Writing too strong next to a line is not review, it is a bottleneck with a deliverable attached. The standards it is read against: In the US, the FTC Health Products Compliance Guidance issued in December 2022, which replaced the 1998 supplement guide and tightened what counts as competent and reliable scientific evidence; FDA's line between structure-function and disease claims, and the disclaimer that has to travel with them; the Health Breach Notification Rule where a wellness app sits inside the funnel. In Canada, section 3 and Schedule A of the Food and Drugs Act, the NNHPD monographs, Ad Standards clearance for consumer drug advertising, and PAAB where the product is prescription. Platform policy sits on top: Google's healthcare and medicines policy with LegitScript certification where it applies, and Meta's health and personal-attribute restrictions, which fail creative on second-person framing more often than on substance. Substantiation gets read, not counted: When a claim rests on a trial, I read the trial. Dose studied against dose delivered. Finished formulation against isolated ingredient. Population, duration, endpoint, and whether the stated endpoint moved or only a subgroup did. A folder of eleven papers supporting a claim none of them tested is the most common thing I find, and the honest disposition there is drop, even when the underlying science is real. Quebec and French copy: French creative is reviewed in French, not run past a translation. Under the Charter of the French Language as amended by Bill 96, French copy for the Quebec market carries obligations the English original does not, and health wording in particular does not survive a literal rendering. Supports and soutient are not interchangeable in front of Ad Standards or the CAI. Not included: I do not manage PAAB or Ad Standards submissions, write regulatory strategy, classify a device, or draft your privacy policy. Nothing I write is legal advice and none of it is privileged; I state in writing that your counsel has the last word. Not for you if: You want the phrasing that lets a disease claim pass as a wellness one. That is the request underneath a lot of this work and the answer is no, without a version of the engagement where it becomes yes. I also decline compounded GLP-1 sold direct to consumer, stem cell clinics, and anything positioned against a cancer diagnosis.