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Marketing personalized products: advertise the method, not a miracle
With personalized products, the result is not known before the analysis – so advertise the method: which data go in and how the formula is calculated. Health claims for supplements are only permitted if they are authorized (Art. 10(1) Regulation (EC) No 1924/2006), ideally in the official wording and only for nutrients that the individual formula actually contains. Disease claims are off-limits, and legal requirements are not a selling point. Describe genetic analyses instead of promising results; in Switzerland, advertising for them needs mandatory information (Art. 14 GUMG). Anyone who earns from orders labels advertising as such.
The optician advertises the eye exam, not the lens
No optician promises you a specific lens in the shop window. They do not yet know what your eyes need. They advertise what they can reliably deliver: a precise eye exam and a lens that is then made for you.
Personalized products work the same way. Before the analysis, nobody knows what will end up in your customer’s formula. A promise about the result would be guesswork – and often not permitted. What you can say with confidence is the method: which data go in, how the calculation works and what arrives at the end. That is honest, legally sound and convincing, because it explains why the product fits this particular person.
Every product page is advertising
In e-commerce, the product page is your sales conversation. Product titles, images and descriptions are advertising – the same rules apply as on the packaging, in your own shop just as on a marketplace.
For foods, there is an additional duty: in distance selling, the mandatory food information – except for the best-before date – must be available before the purchase contract is concluded, and all mandatory particulars at the latest at delivery (Art. 14(1) Regulation (EU) No 1169/2011). Responsibility for food information lies with the food business operator under whose name the food is marketed (Art. 8(1)) – with white label, that is your brand. With personalized products, the formula only comes into being after the analysis. So clarify with Novogenia how the mandatory information on each individual formula is made available before purchase. More in Food supplement labeling requirements.
Describe, do not diagnose
The method is your strongest argument – and you can explain it in concrete terms. At Novogenia, the formula takes into account about 50 genes, a questionnaire and, if available, blood values, which take precedence. The dosage ranges from about one third to, where the data justify it, three times the reference intake – never above the EFSA tolerable upper intake level (UL). The nutrients come in Microtransporter pellets from 1.6 mm in diameter, in which each nutrient is encapsulated individually. Describe this technology factually and without promises about effects in the body. Background is provided in How a personalized nutrient recipe is calculated and Micronutrient dosing limits.
| Better not | Instead | Why |
|---|---|---|
| “Your genes reveal your nutrient deficiency – your formula fixes it.” | “Your formula is calculated based on your blood values and your questionnaire.” (plus genes, if analyzed) | a description instead of a diagnosis and a promise of cure |
| “The genetic test shows which diseases you are at risk of.” | “The analysis shows how your body processes caffeine, vitamins and fats, for example.” | Lifestyle analyses do not detect diseases. |
| “Finally, the one right diet for you.” | “Recommendations that match your genes – as a logical conclusion, not a guarantee.” | Genes are one factor among many. |
| “Only available from us.” (with white label) | “Under our brand, made in Austria.” (if agreed) | White label is not exclusive – other brands can offer a comparable product. |
The same applies to the report: it is a result, not a diagnosis. Use the standard note that the genetic traits are well documented and that the recommendations derived from them are logical conclusions – not scientifically proven. How to position your brand between white label and your own formula is shown in Building your own online brand.
Health claims: only from the list
Supplements are subject to a positive list: health claims are prohibited unless they are authorized and included in the list of permitted claims (Art. 10(1) Regulation (EC) No 1924/2006). The safest option is the official wording of Regulation (EU) No 432/2012, for example:
- “Vitamin D contributes to the maintenance of normal bones”
- “Vitamin B12 contributes to normal energy-yielding metabolism”
Both claims may only be used for food that is at least a source of the vitamin in question. With personalized products, every formula is different. A nutrient claim therefore only fits a formula that meets this condition; on the general product page, you are better off describing the method. Disease claims are always off-limits: food information must not attribute to any food the property of preventing, treating or curing a human disease – explicitly including advertising (Art. 7(3) and (4) Regulation (EU) No 1169/2011). Equally prohibited are claims about the rate or amount of weight loss and references to recommendations by individual doctors (Art. 12(b) and (c) Regulation (EC) No 1924/2006).
For cosmetics, advertising must not imply that a product has characteristics or functions it does not have (Art. 20(1) Regulation (EC) No 1223/2009). With BeautyMe, you can state factually what it is: a day serum, a night serum and a body lotion for which the genetic result determines the selection and dosage of the active ingredients. More in Advertising cosmetics.
Switzerland: Health claims are only permitted if they are provided for in Annex 14 of the Swiss Food Information Ordinance (LIV); other claims need authorization from the Federal Food Safety and Veterinary Office (Art. 31(2) and (3) LIV). References to preventing, treating or curing a disease are prohibited (Art. 12(2)(c) of the Swiss Foodstuffs and Utility Articles Ordinance, LGV).
What is required by law is not a selling point
In e-commerce, it is tempting to advertise things that apply anyway. That is misleading:
- Legal rights: Presenting rights given to consumers in law as a distinctive feature of the trader’s offer is always prohibited (Annex I No. 10 Directive 2005/29/EC; Germany Annex No. 10 UWG; Austria Annex No. 10 UWG). “With 14-day returns” as a highlight is therefore not a good idea – and for personalized products, there is no such right anyway.
- Legal product requirements: It is equally prohibited to present requirements imposed by law on all products within the relevant product category on the Union market as a distinctive feature of your offer (Annex I No. 10a Directive 2005/29/EC; Germany Annex No. 10a UWG; Austria Annex No. 10a UWG).
- Foods: Food information must not suggest that a food possesses special characteristics when in fact all similar foods possess them (Art. 7(1)(c) Regulation (EU) No 1169/2011). Switzerland prohibits this as well, but explicitly allows references to the rules that apply to a food group (Art. 12(2)(b) LGV).
- Cosmetics: Claims that convey the idea that a product has a specific benefit when this benefit is mere compliance with minimum legal requirements are not allowed (Annex, criterion 1(3) Regulation (EU) No 655/2013).
What truly sets your product apart is the personalization. Talk about that – it is enough.
Advertising genetic analyses: lifestyle, not medicine
For the analysis itself, the rule of thumb is: describe what the analysis shows – do not promise results. Retail deals exclusively in non-medical analyses; medical genetic analyses belong in a physician’s hands wherever the law requires it. Advertising that plays on the fear of disease therefore does not fit a lifestyle analysis.
- Germany: As soon as an advertising statement refers to the detection, elimination or alleviation of diseases, the German Act on Advertising in the Healthcare Sector (HWG) also applies to procedures (Section 1(1) no. 2(a) HWG). A sentence like “spots risks before you get sick” therefore pulls a lifestyle analysis into an entirely different set of rules.
- Switzerland: Public advertising for genetic tests in the medical field is prohibited (Art. 14(1) GUMG). Advertising for tests outside the medical field must, among other things, provide information on the requirements for ordering, informing the person and communicating the result (Art. 14(3) GUMG, Art. 4(2) GUMV). Advertising through electronic media explicitly counts as public advertising (Art. 4(3) GUMV). An ad aimed at customers in Switzerland therefore states, for example, that only authorized health professionals may order the analysis and that the sample is taken in their presence.
Which analyses you may offer where is explained in Selling genetic tests online: DE, AT, CH; more wording examples are in Advertising genetic tests.
Influencers and partners: an ad is still an ad
For Novogenia, influencers are a partner type of their own. They have two routes: their own branded partner shop with a commission per order under the partner terms, or their own brand via white label. Either way, anyone who earns from orders is advertising – and must make that recognizable. In Germany, consideration is even presumed (Section 5a(4) UWG); Austria regulates labeling in Section 2(4) no. 2 UWG, and Switzerland prohibits any deceptive conduct in business (Art. 2 UWG).
As a brand, you are responsible for what is said in your name. Give everyone who promotes your product – team, agency, influencers – a list of the phrases they may use, and have posts approved before publication, including images, graphics and symbols. What is allowed in posts, stories and chats is explained in detail in Social media: what distributors may say.
Reviews and case examples: a shop window that has to be true
- Disclose your checks: If you publish customer reviews, you must state whether and how you ensure that they come from people who actually used or bought the product (Section 5b(3) UWG; Austria Section 2(6b) UWG).
- Real voices only: Fake reviews are always prohibited, as is claiming that reviews come from real buyers without reasonable checks (Germany Annex No. 23b and 23c UWG; Austria Annex No. 23b and 23c UWG).
- No cure through the back door: Even a genuine review that mentions a disease has no place in your advertising. Clearly label customer reviews as your customers’ opinions.
- Case examples stay case examples: The stories on Novogenia’s product pages are realistic case examples, not real customer testimonials, and the portraits are AI-generated. If you reuse them, keep this note.
Checklist before going live
- Your product page explains the method rather than a result.
- Mandatory information is available before purchase and matches the label.
- Every health claim is authorized, in the official wording, and belongs to a formula that meets the conditions.
- Not a word about preventing, treating or curing diseases – not in images, reviews or comments either.
- Legal rights and requirements are not advertised as special features; “exclusive” only if it is contractually true.
- Genetic analyses are described as lifestyle analyses, with the note on logical conclusions.
- For Switzerland: claims under Annex 14 LIV and mandatory information under Art. 14(3) GUMG.
- Influencers and partners label their ads and use approved wording.
- Reviews are genuine, your checks are disclosed, and case examples are labeled.
Frequently asked questions
May I write that the personal formula makes up for a nutrient deficiency?
Which health claims may I use for personalized supplements?
Does an influencer have to label posts for my shop as advertising?
May I advertise “14-day returns” or “EU-tested quality”?
What applies to advertising genetic analyses in Switzerland?
Related: Social media: what distributors may say · Advertising genetic tests · Health claims: what you may say
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Request a project →Offer for e-commerceNote: 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.