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Social media in direct selling: what distributors may say – and what they may not

Reviewed by Dr. Daniel Wallerstorfer, molecular biologist and founder of Novogenia · Updated: 13 October 2026 · Reading time: 12 min

In short

For food supplements, distributors may only use authorized health claims – safest in the official wording of Regulation (EU) No 432/2012 and only when the conditions of use are met. Off-limits are statements about preventing, treating or curing diseases, claims about the rate or amount of weight loss, and references to recommendations by doctors or other health professionals (Art. 12 of Regulation (EC) No 1924/2006). Anyone who earns from orders makes advertising recognizable as advertising (in Germany Section 5a(4) UWG, in Austria Section 2(4) No. 2 UWG). Switzerland has its own list of claims (Annex 14 LIV) and mandatory information for advertising genetic analyses (Art. 14 GUMG). What works best is a phrase bank of pre-approved wording, plus approval and training.

A network is a megaphone

A photo, an upward arrow, a heart next to a pack: under EU food law, any of these can be a claim. A “claim” is any message or representation that is not mandatory, “including pictorial, graphic or symbolic representation, in any form” (Art. 2(2)(1) of Regulation (EC) No 1924/2006).

In direct selling, every one of these claims gets multiplied. A network works like a megaphone: it makes a message loud – the right one just as much as the wrong one. A good sentence reaches many people in a short time. So does a non-compliant one. And your company can be held responsible for unfair practices by your distributors (more in Law in direct selling).

The good news: the rules are clear enough to turn into a simple routine. This article shows what distributors may say in posts, stories, videos and chats, what is off-limits and how to organize it across your team.

Pre-approved sentences instead of improvising

Food supplements work from a positive list: health claims are prohibited unless they are authorized and included in the list of authorized claims (Art. 10(1)). The safest option is the official wording from Regulation (EU) No 432/2012, for example:

“Magnesium contributes to a reduction of tiredness and fatigue”
“Vitamin C contributes to the normal function of the immune system”
“Zinc contributes to the maintenance of normal skin”

Each of these claims may only be used for food that is at least a source of the nutrient. Anyone advertising with an authorized claim also needs mandatory information, such as a statement on the importance of a varied and balanced diet and a healthy lifestyle (Art. 10(2)). With personalized products, one more rule applies: only talk about nutrients that are actually in the individual customer’s formula.

For the other products, two simple rules help:

Genetic analyses: Describe what the analysis shows – do not promise results. “The analysis shows how your body processes caffeine, vitamins and fats, for example” is a description. “This is how you will finally lose weight” is a promise.
Cosmetics: Advertising must not imply that a product has characteristics or functions it does not have (Art. 20(1) of Regulation (EC) No 1223/2009). For BeautyMe, you can state the facts: a day serum, a night serum and a body lotion, with the genetic result determining the selection and dosage of the active ingredients. More in Advertising cosmetics.

Red lines: diseases, pounds and the white coat

Four limits always apply to food supplements – no matter how well a sentence is meant:

Diseases: Food information shall not attribute to any food the property of preventing, treating or curing a human disease, nor refer to such properties – expressly including advertising (Art. 7(3) and (4) of Regulation (EU) No 1169/2011). Toward consumers, falsely claiming that a product or service can cure illnesses, dysfunctions or malformations is also always prohibited (Annex No. 17 UWG; in Austria Annex No. 17 UWG).
Pounds: Claims which make reference to the rate or amount of weight loss are not allowed (Art. 12(b) of Regulation (EC) No 1924/2006). “Ten pounds off in four weeks” falls under this just as much as a before-and-after photo with a weight figure.
The white coat: Claims which make reference to recommendations of individual doctors or health professionals are not allowed (Art. 12(c)). “My family doctor swears by it” has no place in a post for a food supplement.
Doing without: Claims which suggest that health could be affected by not consuming the food are not allowed (Art. 12(a)).

Switzerland: The same three bans from Art. 12 apply to health claims there (Art. 34(4) of the LIV), and references to preventing, treating or curing a human disease are prohibited (Art. 12(2)(c) of the LGV). Only what is listed in Annex 14 LIV or authorized by the Federal Food Safety and Veterinary Office is allowed (Art. 31(2) and (3) LIV). Many wordings match the EU list – still, check each one.

Advertising must be recognizable as advertising

A distributor who earns from orders is not simply posting as a private person. Their posts have a commercial purpose – and that purpose must be recognizable:

EU: It is misleading to fail to identify the commercial intent of a commercial practice if not already apparent from the context (Art. 7(2) of Directive 2005/29/EC). Falsely representing oneself as a consumer is always prohibited (Annex I, point 22).
Germany: Anyone who fails to identify the commercial purpose of a commercial practice, unless it is evident from the circumstances, acts unfairly (Section 5a(4) UWG). For an act benefiting another company, there is no commercial purpose only if the person acting receives no payment or similar consideration for it – and consideration is presumed. Creating the false impression of acting as a consumer is always prohibited (Annex No. 22 UWG).
Austria: A commercial practice is also misleading if it fails to identify its commercial purpose, unless this is evident from the circumstances (Section 2(4) No. 2 UWG); falsely representing oneself as a consumer is always prohibited (Annex No. 22 UWG).
Switzerland: The UWG has no specific labeling provision like the German one. But any misleading conduct that influences the relationship between suppliers and customers is unfair (Art. 2 UWG) – and an ad that looks like a private tip misleads about its purpose. So label advertising in Switzerland too.

None of these laws prescribes the exact wording of the label. The safest option is a clear label such as “Ad” right at the start of the post, clearly visible and in your audience’s language – not hidden among the hashtags at the end.

Testimonials: a shop window that has to be accurate

Real voices only: Submitting or commissioning fake consumer reviews or endorsements, and misrepresenting consumer reviews in social media to promote sales, is always prohibited (Annex No. 23c UWG; in Austria Annex No. 23c UWG).
Disclose your checks: If you make consumer reviews available, it counts as material information whether and how you ensure that they come from people who actually used or bought the product (Section 5b(3) UWG; in Austria Section 2(6b) UWG).
No cures through the back door: “Since I started taking this, my migraines are gone” is a disease claim – even if the customer said it exactly like that. It has no place in your advertising.
Case examples stay case examples: If you share stories from Novogenia product pages, keep the note that they are realistic case examples with AI-generated portraits, not real customer testimonials.

Posts about genetic analyses: describe, don’t promise

Genetic analyses call for the same attitude as food supplements – plus a few points of their own:

Lifestyle only: Distributors promote non-medical analyses only. Medical analyses are available only through physicians.
No fear: “Find out which disease is lurking in your genes” is not lifestyle advertising. Talk about nutrition, exercise and well-being.
Put it in context: Genes are one factor among many. Recommendations from the analysis are logical conclusions – not scientifically proven. The result is a report, not a diagnosis.
Switzerland: Advertising medical genetic tests to the public is prohibited (Art. 14(1) GUMG). Advertising for non-medical analyses – expressly including via electronic media – must inform about the requirements for ordering the test, providing information and communicating the result, and must not be misleading (Art. 14(3) GUMG, Art. 4(2) and (3) GUMV). So a post there needs mandatory information, for example that only authorized health professionals may order the analysis and that the sample is taken in their presence.

More examples in Advertising genetic tests.

How to organize it: phrase bank, approval, training

Build a phrase bank: A list of permitted wording for each product – health claims in the official wording with their conditions, descriptions of the analyses, functions of the cosmetics. A separate column for Switzerland, based on Annex 14 LIV.
Provide templates: Ready-made, pre-approved texts, images and videos. People with a good template improvise less.
Approve anything new: Have posts approved before they go live – including images, graphics and symbols.
Train before anyone posts: New distributors learn the phrase bank before they start. How to do this is covered in Training your distributors.
Watch and correct: Keep an eye on what is posted under your brand name and react quickly: adjust the post, correct the comment, retrain.
Set consequences: The partner contract states what happens in case of violations.

Do’s and don’ts: wording for posts

The examples are general. Check every statement for your product and your country.

Do	Don’t	Why
“Magnesium contributes to a reduction of tiredness and fatigue.” (if the product is at least a source of magnesium)	“Never tired again!”	Goes beyond the authorized claim (Art. 10(1) Regulation (EC) No 1924/2006)
“Vitamin C contributes to the normal function of the immune system.”	“This will keep you from getting sick this winter.”	Disease claim (Art. 7(3) Regulation (EU) No 1169/2011)
“Ad – I am a distributor for …” at the start of the post	“My honest secret tip” with no mention of the commission	The commercial purpose must be recognizable (Section 5a(4) UWG; Section 2(4) No. 2 UWG in Austria)
“The analysis shows how your body processes caffeine and vitamins, for example.”	“This genetic test detects diseases before they develop.”	Lifestyle analyses do not detect diseases; medical analyses belong in a physician’s hands
“I changed my diet and I move more.”	“Ten pounds off in four weeks!”	No claims about the rate or amount of weight loss (Art. 12(b))
“Our team has completed the NOVO Academy training.” (if true)	“My family doctor swears by it.”	No references to recommendations of individual doctors (Art. 12(c))
A real customer voice without health promises, recognizable as an opinion	Self-written “customer reviews”	Fake reviews are always prohibited (Annex No. 23c UWG)

Checklist before every post

The post is recognizable as advertising – right at the start.
Every health statement comes from the phrase bank, in the official wording, and its conditions are met.
Not a word about preventing, treating or curing diseases – not in images, emojis, comments or testimonials either.
No weight or time figures on weight loss, no before-and-after photos with numbers.
No recommendations by doctors or other health professionals.
Genetic analyses: lifestyle only, described rather than promised, with the note on logical conclusions.
Switzerland: the claim is listed in Annex 14 LIV, and posts on genetic analyses include the mandatory information under Art. 14(3) GUMG and Art. 4 GUMV.
Testimonials are real and free of health promises.
When in doubt: get approval first, then post.

How we do it at Novogenia

How we support you at Novogenia:

Authorized claims: Novogenia’s personalized supplements use authorized nutrient claims only.
Standard note: The genetic traits determined in a genetic analysis are well documented (each gene included is backed by at least three independent studies); recommendations derived from them are logical conclusions, not scientifically proven.
Honest examples: Case stories on our product pages are labeled as realistic case examples, not real customer testimonials; the portraits are AI-generated.
Lifestyle only via distributors: Distributors promote and sell non-medical analyses only – on lifestyle, nutrition, beauty and sport.
Training: The NOVO Academy is free of charge and optional – about 5 hours of video per language, with a certificate for each completed topic, in German, English, Czech, French, Portuguese, Italian and Dutch.
Clear roles: We support you with formula and label. Responsibility for the advertising lies with whoever sells the product under their own name.

Frequently asked questions

Does a distributor have to label posts as advertising?

If they earn from orders, yes. In Germany, anyone who fails to identify the commercial purpose of a commercial practice, unless it is evident from the circumstances, acts unfairly (Section 5a(4) UWG). Austria regulates this in Section 2(4) No. 2 UWG. Switzerland has no specific labeling provision but prohibits any misleading conduct in business (Art. 2 UWG). The safest option is a clear label such as “Ad” right at the start of the post.

Do the rules also apply to stories, comments and private chats?

Yes, as soon as selling is involved. A commercial practice is any act, representation or commercial communication by a trader directly connected with the promotion, sale or supply of a product (Art. 2(d) of Directive 2005/29/EC). The Health Claims Regulation applies to claims made in commercial communications, whether in labeling, presentation or advertising (Art. 1(2) of Regulation (EC) No 1924/2006). A sales conversation in a chat is not a law-free zone.

May I put authorized health claims in my own words?

Only if the meaning stays the same. According to recital 9 of Regulation (EU) No 432/2012, claims that have the same meaning for consumers as an authorized claim are subject to the same conditions of use. But “contributes to the normal function” does not become “boosts” or “protects.” For distributors, the official wording from the phrase bank is the safe route.

May I post how much weight I lost myself?

Not in connection with a food supplement. Health claims that refer to the rate or amount of weight loss are not allowed (Art. 12(b) of Regulation (EC) No 1924/2006); Switzerland has the same rule (Art. 34(4) LIV). Talk instead about what you changed in your diet and exercise – without pounds, kilos or time frames.

What applies to posts in Switzerland?

Health claims are only allowed if they are listed in Annex 14 LIV or authorized by the Federal Food Safety and Veterinary Office (Art. 31(2) and (3) LIV). Claims suggesting that health suffers without the food, weight-loss claims and recommendations by individual doctors are prohibited (Art. 34(4) LIV). Advertising for non-medical genetic analyses needs mandatory information, for example that only authorized health professionals may order them (Art. 14(3) GUMG, Art. 4 GUMV).

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Note: This guide is general information for businesses and professionals and does not replace medical or legal advice. The genetic traits determined in a genetic analysis are well documented (each gene included is backed by at least three independent studies); recommendations derived from them are logical conclusions, not scientifically proven. Regulations can change; errors and changes excepted.