Young Living warning letter points to need among MLMs to have plan to police language used by distributors

By Hank Schultz contact

- Last updated on GMT

©Getty Images - Ildo Frazao
©Getty Images - Ildo Frazao

Related tags: Fda, Dietary supplement, Dietary supplement industry, Food and drug administration, Dietary supplements, disease claims

A warning letter sent to Young Living, a multi level marketing company specializing in essential oils, underscores the importance of having a social media monitoring program in place to avoid running afoul of regulators.

Young Living is one of two MLMs specializing in essential oil products (Doterra being the other).  The company, founded in 1993, has its headquarters in Lehi, UT and sources at least some of its essential oils from its own farm in Idaho.

What the ‘consultants’ are saying

The recent warning letter that came from the US Food and Drug Administration took the company to task over claims being made by some of the company’s ‘consultants.’  (Every MLM has its own terminology to refer to the independent business owners that recruit downline distributors and market products within the company’s network marketing structure.)

FDA cited claims associated with a variety of essential oil products as well as a number of CBD offerings as well as other products.  The claims were being made on the social media accounts maintained by six different consultants.  It’s not clear if all of the consultants still work for the company.

Some of the claims being made on the products included an ability to arrest respiratory infections, benefits for inflammation, anxiety and PTSD, running up to mentions of Alzheimer’s, Parkinson’s and epilepsy.  One particular claim that FDA took notice of was a suggestion of applying Frankincense Essential Oil to the umbilical cord stump on a newborn, which the Agency said carries the risk of infection.

The warning letter asserted that the claims made the products unapproved new drugs.  The offending messages cited by FDA were from posts made between 2018 and 2021.

Having a plan in place

Attorneys contacted by NutraIngredients-USA​ declined to comment on the record, because Young Living is or has been represented by their firms.  But in off the record conversations, they stressed that FDA can send such a warning letter based on monitoring of social media platforms without an inspection or investigation.  

That begs the question of how a company with perhaps tens or hundreds of thousands of distributors can demonstrate a culture of compliance when all of those people can post messages every day.  At any time one of those distributors could go beyond the pale and come to the attention of FDA.

NutraIngredients-USA​’s sources said what the Agency would be looking for in a response to such a warning letter is whether the company has a program of monitoring the social media accounts of its distributors in real time.  This might take the form of frequent monitoring of the, say, top 25 or 50 sellers and a plan for random sampling of what’s being said by the rest.  And, as the Young Living letter makes plain, such a system should also include an framework for scrubbing older messages from accounts.

Young Living has been growing rapidly in recent years.  In 2021 it ranked No. 7 on the Global 100 list of the world’s top MLMs with $2.2 billion in annual revenue.  The list is maintained by industry publication Direct Selling News.  ​Not every MLM (many of which are privately held) chooses to participate every year. In 2017 the company ranked No. 22 with $1 billion in annual revenue. 

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