Longevity marketing has a vocabulary problem. Nearly every phrase that makes a NAD+ drip sound worth several hundred dollars is a structure/function claim — a statement about what the infusion does to the body — and that makes it a drug claim about a product that is not an approved drug for those purposes.
The good news, and it's real: unlike uncleared devices or unapproved biologics, this one is usually fixable. The service can often stay. The copy has to change.
These describe an effect on the structure or function of the body:
And these name a condition, which is a treatment claim:
| Safe | Crosses over |
|---|---|
| "A supervised infusion visit in a calm setting" | "Reverses cellular aging" |
| "Many clients tell us they feel refreshed afterwards" | "Repairs DNA damage" |
| "Your provider will review whether this is appropriate for you" | "Restores mitochondrial function" |
| Describing hydration and the experience | Treating fatigue, brain fog, or any named condition |
"A supervised NAD+ infusion visit, with a provider consultation beforehand. Many clients tell us they leave feeling refreshed. Individual results vary."
Everything you give up by dropping the mechanism claims, you can win back with specifics about the experience: the consultation, the supervision, the room, the time, who is monitoring you. That's what people are actually buying, and none of it is regulated speech.
Testimonials carry the claim. A patient saying "it cured my brain fog" on your site is your claim once you publish it. Endorsement rules mean you own what your testimonials assert.
IV therapy has separate exposure. Beyond the marketing language, IV services raise questions about scope of practice, supervision, and who may place a line — which vary by state and are enforced by your board, not FDA. The copy fix doesn't touch any of that.
Educational information about publicly available regulatory frameworks — not legal advice. Scope-of-practice and supervision questions should go to your state board or qualified counsel.
This article is educational content about publicly available regulatory guidance. It is not legal advice; consult healthcare counsel for guidance specific to your practice.
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