Diligence review · target · Delivered
Demo portfolio
Exhibit delivered · latest scan Sep 30, 2026
Exhibit delivered
Found across the portfolio
348 Critical
8 Critical · 19 High · 7 Medium
Category rank
#11riskiest 6%
Of 194 Immune listings · 1 is riskiest
AI answers
1 / 61 flagged
6 assistants asked as a shopper would
Sample data.
Since you last lookedSample visit, 27 Sep
Portfolio
Every product in scope, ruled on the same 109 standards and ordered by exposure: what a platform’s AI, a processor or a regulator can act on after the deal closes. Open a product for its claims and the fix for each.
3Products reviewed
8Critical across the portfolio
19High
34Claims to remediate
Product A · Amazon listingImmune support, 90 capsules
6 Critical9 High3 Medium
Immune support, 90 capsules
Critical
“fight back against symptoms of seasonal sniffles”
Implies the product fights symptoms of colds, an infectious disease claim.
→ “Supports immune function”
Critical
“help combat symptoms related to common seasonal conditions”
Combating symptoms of seasonal illness is a disease/symptom-relief claim.
→ “Supports healthy immune function”
Critical
“helps give your immune system the extra support it needs to fight back against symptoms”
Symptom-fighting language is drug-claim framing.
→ Remove, and use 'supports healthy immune function'
Critical
“keep you protected year round”
Implies prevention of illness, a drug claim.
→ “Supports healthy immune function”
Critical
“Whether you need extra protection at home, school or on the go”
Implies protection from getting sick, a prevention claim.
→ “Supports healthy immune function”
Critical
“features ingredients with powerful natural properties to protect your respiratory system”
Claiming to protect a body system implies prevention of disease.
→ “Supports respiratory health”
High
“Immunity Boost for Adults”
'Boost' implies enhancement of the immune system beyond normal function rather than support.
→ “Supports healthy immune function”
High
“Demo brand immunity boost defense formula”
'Immunity boost' reads as an enhancement claim on the immune system.
→ “Supports healthy immune function”
High
“clean & ultra pure immunity boost”
'Immunity boost' is an immune-booster claim.
→ “Supports healthy immune function”
High
“immunity boost”
'Immunity boost' is an immune-booster claim.
→ “Supports healthy immune function”
High
“Demo brand immunity boost formula”
'Immunity boost' is an immune-booster claim.
→ “Supports healthy immune function”
High
“Demo brand immunity boost capsules”
'Immunity boost' is an immune-booster claim.
→ “Supports healthy immune function”
High
“PURE IMMUNITY BOOSTER FORMULA”
'Immunity booster' claims enhancement of the immune system.
→ “Supports healthy immune function”
High
“our formula works at a cellular level to fortify your immune system”
Fortifying/strengthening the immune system implies action beyond normal support.
→ “Supports healthy immune function”
High
“Our professional grade immune support supplements”
'Professional grade' has no defined meaning and implies drug-equivalent quality.
→ “Third-party tested for purity and potency”
Medium
“manufactured without gmos”
Non-GMO claims require one of Amazon's three accepted documentation forms.
→ Hold accepted documentation or remove the claim.
Medium
“make all our supplements to exceed expectations set by cGMP (Current Good Manufacturing Practices)”
Unverified cGMP superiority claim without third-party certification documentation.
→ “Manufactured in a cGMP-compliant facility”
Medium
“made in the USA with the finest quality globally sourced ingredients”
Unsubstantiated superiority claim about ingredient quality.
→ Describe the sourcing standard specifically.
Product B · Amazon listingCortisol support, magnesium glycinate
1 Critical5 High3 Medium
Cortisol support, magnesium glycinate
Critical
“Demo Cortisol-Calm Supplement”
Product name implies soothing/lowering cortisol, a physiological correction claim built into the name.
→ Rename to avoid implying a therapeutic effect on cortisol.
High
“cortisol balance and adrenal health”
'Balance' of a hormone implies correcting a pathological imbalance.
→ “Supports healthy hormone levels”
High
“enhances your body’s natural ability to regulate cortisol”
'Regulates' a hormone implies pharmacological control.
→ “Supports healthy hormone levels”
High
“promote cortisol balance and support adrenal health”
Hormone-balance framing implies correcting an abnormal state.
→ “Supports healthy hormone levels”
High
“This formula helps lower cortisol, stabilize mood”
Claiming to lower a measured hormone level and stabilize mood is a pharmacological/disease-adjacent claim.
→ “Helps the body adapt to occasional stress and supports a positive mood”
High
“helps maintain balanced cortisol levels”
Implies correction/normalization of hormone levels.
→ “Helps maintain cortisol levels already within the normal range”
Medium
“making it a superior alternative to traditional cortisol cocktails”
Unsubstantiated superiority comparison.
→ Describe the formulation specifically instead of comparatively.
Medium
“offers a natural, effective alternative to cortisol cocktails”
Comparative effectiveness claim without head-to-head evidence.
→ Describe the formulation specifically instead of comparatively.
Medium
“Magnesium Glycinate 200mg L-Theanine 150mg Ashwagandha 150mg”
Ingredient weights are given without stating per serving or per capsule.
→ Attach the portion to every weight: per serving or per capsule, matching the panel.
Product C · Amazon listingCortisol support for women, 120 capsules
1 Critical5 High1 Medium
Cortisol support for women, 120 capsules
Critical
“Made for adrenal fatigue”
'Adrenal fatigue' names a purported endocrine disease state, making this a disease claim.
→ “Supports healthy adrenal function”
High
“Botanical hormone balance blend”
'Hormone balance' implies correcting a pathological hormonal imbalance.
→ “Supports healthy hormone levels”
High
“Restore true cortisol balance and bring your levels back into harmony”
'Restore' implies correcting an abnormal cortisol state.
→ “Helps maintain cortisol levels already within the normal range”
High
“a natural blend made to regulate your cortisol”
'Regulate' implies pharmacological control of a hormone level.
→ “Supports healthy cortisol levels”
High
“Plus the immune-boosting power of vitamin C”
'Immune-boosting' implies enhancement beyond normal immune function.
→ “Supports healthy immune function”
High
“Results you can count on!”
An unqualified promise of results is a guarantee the evidence would have to back.
→ Remove.
Medium
“No GMOs, no artificial additives”
Non-GMO claim requires one of Amazon's three accepted documentation forms.
→ Hold accepted documentation before the claim runs, or remove.
Ask about a claim
Paste a line you want to publish. It is ruled against the same 109 standards as your audit, with the rule cited, and failing lines come back with rewrites checked again. Answers usually arrive within a few minutes. A licensed pharmacist reviews any answer on request.
Answers come from AI software. The pharmacist does not review an answer unless you ask for that in your file.
Every question on this file, oldest first
You asked · Oct 5, 10:57 · answered Oct 5, 10:59
AllowedAI only“Our ashwagandha gummies support restful sleep”
Allowed
No findings · 109 standards
Keep the FDA disclaimer wherever this runs as a structure/function claim.
This answer comes from AI software. The pharmacist does not review it unless you ask for that in your file.
Instant ruling · unsigned
You asked · Oct 5, 13:57 · answered Oct 5, 13:59
Needs changesPharmacist-reviewed“Can we say our formula balances cortisol and reduces anxiety?”
Critical
treats anxiety / for anxiety · CV-NC-01
Anxiety is a named condition. Claiming to reduce it is a disease claim.
Rule source: 21 CFR 101.93(g) · FDCA s.201(g)(1)(B)
High
balances hormones · CV-ID-08
"Balance" implies correcting a pathological imbalance.
Rule source: 21 CFR 101.93(g)
Options within the rules, each checked again
Safest
Helps the body adapt to occasional stress.
Amazon listing · Label (with the FDA disclaimer) · Website · Ads · Email · checked again: no findings
Balanced
Promotes a sense of calm and helps the body adapt to occasional stress.
Amazon listing · Label (with the FDA disclaimer) · Website · Ads · Email · checked again: no findings
Strongest allowed
Supports healthy cortisol levels already within the normal range and promotes a sense of calm.
Amazon listing · Label (with the FDA disclaimer) · Website · Ads · Email · checked again: no findings
This answer came from AI software and was then reviewed by the pharmacist.
Signed by the licensed pharmacist · Oct 5Reviewer note: Use the safest option on the label.
Findings and fixes
34 findings from the scan on Sep 30, 2026, ruled against standards v1.4.1.
CriticalProduct A · Amazon listing · CV-NC-20
“fight back against symptoms of seasonal sniffles”
→ “Supports immune function”
Implies the product fights symptoms of colds, an infectious disease claim. Can lead to: FDA: a warning letter treating it as a drug claim, Health Canada: a Schedule A advertising finding, Amazon: listing suppression.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
CriticalProduct A · Amazon listing · CV-NC-20
“help combat symptoms related to common seasonal conditions”
→ “Supports healthy immune function”
Combating symptoms of seasonal illness is a disease/symptom-relief claim. Can lead to: FDA: a warning letter treating it as a drug claim, Health Canada: a Schedule A advertising finding, Amazon: listing suppression.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
CriticalProduct A · Amazon listing · CV-DV-09
“helps give your immune system the extra support it needs to fight back against symptoms”
→ Remove, and use 'supports healthy immune function'
Symptom-fighting language is drug-claim framing. Can lead to: FDA: a warning letter treating it as a drug claim, Health Canada: a Schedule A advertising finding, Amazon: listing suppression.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
CriticalProduct A · Amazon listing · CV-DV-03
“keep you protected year round”
→ “Supports healthy immune function”
Implies prevention of illness, a drug claim. Can lead to: FDA: a warning letter treating it as a drug claim, Health Canada: a Schedule A advertising finding, Amazon: listing suppression.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
CriticalProduct A · Amazon listing · CV-DV-03
“Whether you need extra protection at home, school or on the go”
→ “Supports healthy immune function”
Implies protection from getting sick, a prevention claim. Can lead to: FDA: a warning letter treating it as a drug claim, Health Canada: a Schedule A advertising finding, Amazon: listing suppression.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
CriticalProduct A · Amazon listing · CV-DV-03
“features ingredients with powerful natural properties to protect your respiratory system”
→ “Supports respiratory health”
Claiming to protect a body system implies prevention of disease. Can lead to: FDA: a warning letter treating it as a drug claim, Health Canada: a Schedule A advertising finding, Amazon: listing suppression.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
CriticalProduct B · Amazon listing · CV-IC-02
“Demo Cortisol-Calm Supplement”
→ Rename to avoid implying a therapeutic effect on cortisol.
Product name implies soothing/lowering cortisol, a physiological correction claim built into the name. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: 21 CFR 101.93(g)
CriticalProduct C · Amazon listing · CV-NC-18
“Made for adrenal fatigue”
→ “Supports healthy adrenal function”
'Adrenal fatigue' names a purported endocrine disease state, making this a disease claim. Can lead to: FDA: a warning letter treating it as a drug claim, Health Canada: a Schedule A advertising finding, Amazon: listing suppression.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-07
“Immunity Boost for Adults”
→ “Supports healthy immune function”
'Boost' implies enhancement of the immune system beyond normal function rather than support. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-07
“Demo brand immunity boost defense formula”
→ “Supports healthy immune function”
'Immunity boost' reads as an enhancement claim on the immune system. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-07
“clean & ultra pure immunity boost”
→ “Supports healthy immune function”
'Immunity boost' is an immune-booster claim. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-07
“immunity boost”
→ “Supports healthy immune function”
'Immunity boost' is an immune-booster claim. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-07
“Demo brand immunity boost formula”
→ “Supports healthy immune function”
'Immunity boost' is an immune-booster claim. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-07
“Demo brand immunity boost capsules”
→ “Supports healthy immune function”
'Immunity boost' is an immune-booster claim. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-07
“PURE IMMUNITY BOOSTER FORMULA”
→ “Supports healthy immune function”
'Immunity booster' claims enhancement of the immune system. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-10
“our formula works at a cellular level to fortify your immune system”
→ “Supports healthy immune function”
Fortifying/strengthening the immune system implies action beyond normal support. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct A · Amazon listing · CV-ID-12
“Our professional grade immune support supplements”
→ “Third-party tested for purity and potency”
'Professional grade' has no defined meaning and implies drug-equivalent quality. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct B · Amazon listing · CV-ID-08
“cortisol balance and adrenal health”
→ “Supports healthy hormone levels”
'Balance' of a hormone implies correcting a pathological imbalance. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct B · Amazon listing · CV-ID-08
“enhances your body’s natural ability to regulate cortisol”
→ “Supports healthy hormone levels”
'Regulates' a hormone implies pharmacological control. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct B · Amazon listing · CV-ID-08
“promote cortisol balance and support adrenal health”
→ “Supports healthy hormone levels”
Hormone-balance framing implies correcting an abnormal state. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct B · Amazon listing · CV-ID-08
“This formula helps lower cortisol, stabilize mood”
→ “Helps the body adapt to occasional stress and supports a positive mood”
Claiming to lower a measured hormone level and stabilize mood is a pharmacological/disease-adjacent claim. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct B · Amazon listing · CV-ID-10
“helps maintain balanced cortisol levels”
→ “Helps maintain cortisol levels already within the normal range”
Implies correction/normalization of hormone levels. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct C · Amazon listing · CV-ID-08
“Botanical hormone balance blend”
→ “Supports healthy hormone levels”
'Hormone balance' implies correcting a pathological hormonal imbalance. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct C · Amazon listing · CV-ID-10
“Restore true cortisol balance and bring your levels back into harmony”
→ “Helps maintain cortisol levels already within the normal range”
'Restore' implies correcting an abnormal cortisol state. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct C · Amazon listing · CV-ID-08
“a natural blend made to regulate your cortisol”
→ “Supports healthy cortisol levels”
'Regulate' implies pharmacological control of a hormone level. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct C · Amazon listing · CV-ID-07
“Plus the immune-boosting power of vitamin C”
→ “Supports healthy immune function”
'Immune-boosting' implies enhancement beyond normal immune function. Can lead to: FDA: a warning letter treating it as a drug claim.
Rule source: FDCA s.201(g)(1)(B), 21 U.S.C. 321(g)(1)(B)
HighProduct C · Amazon listing · CV-FR-06
“Results you can count on!”
→ Remove.
An unqualified promise of results is a guarantee the evidence would have to back. Can lead to: FTC: a demand for the substantiation.
Rule source: FTC Act s.5(a), 15 U.S.C. 45(a)
MediumProduct A · Amazon listing · CV-SB-12
“manufactured without gmos”
→ Hold accepted documentation or remove the claim.
Non-GMO claims require one of Amazon's three accepted documentation forms. Can lead to: FTC: a demand for the substantiation, Ad Standards Canada: a complaint, Amazon: listing suppression, Walmart: listing removal.
Rule source: FTC Act s.5(a), 15 U.S.C. 45(a)
MediumProduct C · Amazon listing · CV-SB-12
“No GMOs, no artificial additives”
→ Hold accepted documentation before the claim runs, or remove.
Non-GMO claim requires one of Amazon's three accepted documentation forms. Can lead to: FTC: a demand for the substantiation, Ad Standards Canada: a complaint, Amazon: listing suppression, Walmart: listing removal.
Rule source: FTC Act s.5(a), 15 U.S.C. 45(a)
MediumProduct A · Amazon listing · CV-FR-08
“make all our supplements to exceed expectations set by cGMP (Current Good Manufacturing Practices)”
→ “Manufactured in a cGMP-compliant facility”
Unverified cGMP superiority claim without third-party certification documentation. Can lead to: FDA: a challenge if your facility records do not back it, FTC: a demand for the substantiation.
Rule source: 21 CFR Part 111
MediumProduct A · Amazon listing · CV-SB-02
“made in the USA with the finest quality globally sourced ingredients”
→ Describe the sourcing standard specifically.
Unsubstantiated superiority claim about ingredient quality. Can lead to: FTC: a demand for the substantiation, Amazon: listing suppression.
Rule source: FTC Act s.5(a), 15 U.S.C. 45(a)
MediumProduct B · Amazon listing · CV-SB-02
“making it a superior alternative to traditional cortisol cocktails”
→ Describe the formulation specifically instead of comparatively.
Unsubstantiated superiority comparison. Can lead to: FTC: a demand for the substantiation, Amazon: listing suppression.
Rule source: FTC Act s.5(a), 15 U.S.C. 45(a)
MediumProduct B · Amazon listing · CV-SB-02
“offers a natural, effective alternative to cortisol cocktails”
→ Describe the formulation specifically instead of comparatively.
Comparative effectiveness claim without head-to-head evidence. Can lead to: FTC: a demand for the substantiation, Amazon: listing suppression.
Rule source: FTC Act s.5(a), 15 U.S.C. 45(a)
MediumProduct B · Amazon listing · CV-LR-03
“Magnesium Glycinate 200mg L-Theanine 150mg Ashwagandha 150mg”
→ Attach the portion to every weight: per serving or per capsule, matching the panel.
Ingredient weights are given without stating per serving or per capsule. Can lead to: Amazon: listing suppression.
Diligence exhibit
Your signed exhibit for the deal room. Confidential: for you, your advisers and anyone else under the deal’s NDA.
Diligence exhibitCurrent
client_report_diligence_demo_portfolio.pdf · signed Oct 2, 2026
Open the sample →
Claim memory
Every line a pharmacist has cleared for Demo portfolio, kept here to reuse across new ads and listings.
Copy any line. Structure/function lines carry the FDA disclaimer wherever they run.
Supports immune function
Listing · Label (with the FDA disclaimer) · Website · Ads · Email
Signed
Supports healthy immune function
Listing · Label (with the FDA disclaimer) · Website · Ads · Email
Signed
Supports respiratory health
Listing · Label (with the FDA disclaimer) · Website · Ads · Email
Signed
Supports healthy adrenal function
Listing · Label (with the FDA disclaimer) · Website · Ads · Email
Signed
Third-party tested for purity and potency
Listing · Label · Website · Ads · Email
Signed
Supports healthy hormone levels
Listing · Label (with the FDA disclaimer) · Website · Ads · Email
Signed
Helps the body adapt to occasional stress and supports a positive mood
Listing · Label (with the FDA disclaimer) · Website · Ads · Email
Signed
Helps maintain cortisol levels already within the normal range
Listing · Label (with the FDA disclaimer) · Website · Ads · Email
Signed
Supports healthy cortisol levels
Listing · Label (with the FDA disclaimer) · Website · Ads · Email
Signed
Manufactured in a cGMP-compliant facility
Listing · Label · Website · Ads · Email
Signed
AI answers
What 6 assistants tell a shopper who asks about Demo portfolio: ChatGPT, Claude, Gemini, Perplexity, Grok, Alexa for Shopping. Alexa for Shopping (formerly Rufus) is Amazon’s own AI reading your listing to shoppers.
HighFixed
“ChatGPT: "It is known to boost immunity and help fight off colds."”
Repeated a cold claim your audit removed, drawn from an old product page that was still live. The page was taken down and ChatGPT re-tested on Oct 1.
→ Now: “It is marketed as supporting healthy immune function.”
MediumFlagged
“Alexa for Shopping: "Customers say it is clinically proven."”
Drawn from a customer review, not your copy. It is not a claim you made, so it is flagged for you to watch rather than fixed.
Category rank
Risk rank among 194 top-selling Immune listings for the first product. 1 is riskiest.
Product A · Immune support, 90 capsules
Scanned 2026-09-30
#11
Riskiest 6% of the category
Product B · Cortisol support, magnesium glycinate
Scanned 2026-09-30
#20
Riskiest 5% of the category
Product C · Cortisol support for women, 120 capsules
Scanned 2026-09-30
#28
Riskiest 7% of the category
Label and licence checks
What sits outside the listing copy: product names that are claims in themselves, and any public FDA warning letter naming the target or its brands.
Product names: one is a claim in itself (Product B), which means a rename, new packaging and trademark work, the costliest fix in the file.
FDA warning letters: no public letter names the target or its brands.
Change history
Every step on your file, dated. Every ruling in it carries the standards version it was made under.
Oct 2PharmacistDiligence exhibit signed and delivered
Sep 30EnginePortfolio scanned: 3 Amazon listings
Sep 29EngineScope confirmed: 3 Amazon listings
Sep 28YouFile opened