On the most recent list of FDA Warning Letters was Science Diet.  The FDA is not pleased at how Science Diet promotes/advertises their “Healthy Mobility Diet”.  Here’s what the FDA said…

From the FDA Warning Letter to Science Diet dated 11/23/11…
Based on claims made by Hill’s Pet Nutrition for this product, the Healthy Mobility Diet is a drug under section 201(g)(1)(B) of the Federal Food, Drug and Cosmetic Act (“FD&C Act”), [21 U.S.C. § 321 (g)(1)(B)], as it is intended for use in the mitigation and treatment of joint disease in dogs.   As discussed below, this product is an unapproved new animal drug and your marketing of it violates the FD&C Act.

The Healthy Mobility Diet bears the following claims on its label:
•    “Tested nutrition to enhance active mobility in just 30 days”
•    “Improves joint flexibility in just 30 days”
•    “Enhance active mobility in just 30 days
Vital fatty acids
Optimal levels of Omega-3 fatty acids to enhance overall mobility”
•    “Improve joint flexibility in just 30 days
Omega-3 fatty acids plus Glucosamine & Chondroitin Sulfate
Natural key building blocks of healthy cartilage and joint function”

“Numerous other statements made on the Hill’s Pet Nutrition website to promote the Healthy Mobility Diet indicate that it is intended to mitigate or treat disease.”  The FDA does not allow any product – human or pet – to make statements of curing a disease unless it is a drug (which has gone through expensive approval trials).

And the FDA cites many more instances of Science Diet pushing the line with the marketing of Healthy Mobility.

To explain a little further, the FDA does not consider food as healing; that food could cure or improve a disease or illness.  I disagree with this belief, but that aside, it is the FDA’s position that anything that cures or heals a disease or ailment would be considered a drug.  Thus, if it is a drug, the drug must go through FDA approval process.  As an example, with Science Diet’s claim of “improve joint flexibility in just 30 days!” – the FDA considers this to be a drug claim – thus it is not allowed for a food to make such a claim.

Science Diet should have known better.  They have been in the pet food business for too long now not to understand FDA’s perspective on health claims.

As of today 12/2, it does not appear that Science Diet has removed any of the marketing statements the FDA addressed in the Warning Letter.  Per the Warning Letter, Science Diet has 15 working days to respond.  It will be interesting to see if Science Diet will remove these marketing terms or if the FDA will cave to Science Diet.  We’ll see.