Great keyword phrases you can’t use: FDA regulations & SEO

Just recently I received the keyword research from a client. For one of the products I’m working on, a natural supplement that cures yeast infections, his researcher dug up the term “yeast infection remedy” which has a global monthly search volume of 45,000 and a KEI (Keyword Effectiveness of) of .51 and the term “yeast infection home remedy” which has a global monthly search volume 12,100 and a KEI of .11.

Now any SEO copywriter would ordinarily be pretty happy about working on these terms – high search volume and relatively low competition.

And when I looked over the dozens of glowing testimonials for the product, I could see many of those thousands of searchers would be ecstatic to find my client’s product.

As a health writer of close to 15 years, I know how frustrating chronic yeast infections are. I also know how ineffective prescription and over-the-counter drugs are for dealing with chronic candida (yeast). Not to mention the terrible side effects they bring.

My client’s natural health supplement product page was the perfect page to satisfy these thousands of search queries.

However, despite all the factors that made these keyword phrases ideal, I had to pass them over...

I had to keep looking for keyword phrases.

Even more heartbreaking . . . by doing so I had to ignore those thousands of women looking for an effective natural treatment for yeast infection. Hopefully, they’ll find their way to the product pages I’m working on. But it wouldn’t be through these keyword phrases. Or at least not directly.

Because here’s the frustrating thing about working as an SEO copywriter in the natural supplements industry . . .

Many Good Keyword Phrases Are Illegal For Nutritional Supplement Copy

Legally, with a few exceptions, we can’t refer to diseases in our marketing copy.

I’d rather that refer to diseases in our marketing copy.  In 1994, a compromise piece of legislation was passed into law, the Dietary Supplement Health and Education Act (DSHEA). DSHEA acknowledged that natural products, many of them foods we eat with a history of safe use, did not need to go through the same regulatory process as the synthetic chemicals never before introduced to the human body that the pharmaceutical industry sold.

However, as part of this compromise, supplements were distinguished from drugs by defining drugs as the only substances that can cure, prevent or alleviate the symptoms of a disease. Despite literally hundreds of thousands of published studies showing they help with diseases, supplements can only be discussed with reference to how they support a normal, healthy structure or function in the body.

Violators of this distinction will first receive a warning letter from the Food And Drug Administration (FDA), advising them to change their marketing copy. And if they don’t make the changes within the 30-day time limit imposed by the FDA, they can be subject to fines, product seizure and worse.

Just recently, a family-owned supplement company endorsed by several autism groups experienced how bad this could get. Hundreds of parents had written letters to them about how effective their supplements were in helping their children. These supplements had been carefully developed by an MIT researcher for brain health and digestive health.

However, because the company violated DSHEA by mentioning autism in their descriptions, including the autism organization endorsements and the hundreds of testimonials from families, they received an FDA warning letter.  Upon receipt of this letter, they diligently began editing their website in order to meet FDA requirements. But because they had failed to remove all the glowing letters and testimonials from grateful parents within the 30-day deadline, armed FDA enforcement officers showed up at their business and seized not only their products but also all their computers and files.

Because of these legalities, writing SEO copy for supplement companies is fraught with difficulties. And it is something not to take lightly.

2 Ways To Get Good Traffic Despite FDA Restrictions

However, there are some ways to work within these regulations and still tap into some organic traffic.

The first way is to focus on the positive benefits of the product.

Any good copywriter focuses on benefits. With DSHEA, you have to focus on them specifically in a positive light.  Instead of optimizing for “arthritis cure” or “end joint pain”, optimize for “joint comfort”.  Instead of optimizing for “heart disease ” you optimize for “heart health”.

Sure, it’s not as satisfying. And you’ll have to pass over some great keyword phrases. But you can still get some pretty good search volume with this tactic and stay FDA compliant.

However, many companies use a second approach that allows them to optimize for these disease claims.

It’s called the two-click rule. While not coded into law, it’s a standard practice that so far seems to fit within DSHEA requirements.

Essentially, the two-click rule goes like this: As long as you keep references to disease claims two clicks away from any references to a branded product, it’s okay.

So while you may not be able to optimize a product page or even a category page for some of the keyword phrases that reference diseases, you can create a well-optimized article for these phrases. Then you need to make sure that there are no references to the branded product on the article page or on any pages it’s linked to.

While this still means a more convoluted pathway to converting organic visitors to customers, it allows nutritional supplement websites to optimize for certain disease claims.

To accommodate this rule, some manufacturers have gone as far to create separate educationally-focused websites where they can freely discuss their product’s ingredients. They can reference any research that demonstrates how these ingredients help with diseases.

While this helps pull traffic into their sites, it’s still hard to make the eventual connection that converts to a sale. So many ecommerce sites focus on capturing leads with an enticing optin offer.  They can eventually introduce these prospects to their product in follow-up email marketing.

In fact even the report and squeeze page can freely discuss the product ingredients’ effectiveness in combating a disease. As long as the branded product isn’t mentioned.

For example, a manufacturer can tap into the wealth of research demonstrating Vitamin D and probiotics help reduce the incidence and virulence of the flu. As long as no mention is made in the report of the branded formulation they sell that combines the two.

They can then introduce subscribers to this product in a subsequent email.

Some Cautions To Keep In Mind

While this rule is applied by many an ecommerce site, there are two cautions to keep in mind:

  1. The two-click rule is standard practice but it’s not coded into law. So while the FDA seems to be allowing this as a common practice, there is no legal code that protects you if the FDA decides to change their perspective.
  2. FDA lawyers I’ve consulted with also advise caution in the free report scenario. They advise that if you go this route, you need to make sure that the majority of the follow-up emails you send are educational – not promotional. Otherwise the FDA might make the case that you are using disease claims as part of your overall marketing message.

Finally, in general, I always advise my clients to secure the services of an FDA lawyer to review copy I write. And I include in my contract that while I strive to be FDA-compliant, I am not a legal expert and not liable for the legality of the copy I write for them.

There are many gray areas. And the FDA’s interpretation of what’s considered a disease claim often changes over time. For example, only a few years back, high cholesterol wasn’t considered a disease. That is, until the FDA defined high cholesterol as the disease, hypercholesterolemia. Now you cannot discuss it in marketing copy.

While your job is to write for compliance and be somewhat familiar with the restrictions, you should not be responsible for the ultimate assessment in whether the copy is legal or not. And if your client cannot or decides not to secure legal counsel, you need to make it clear that you are not ultimately responsible for the legality of the copy.

An Industry Desperate For Good SEO Copywriters

Ultimately, I love writing about nutritional supplements. I love digging into the science behind why they work and helping people find viable solutions that are healthy, safe, effective and affordable. My family has experienced remarkable cures thanks to what I’ve learned about supplements and nutrition.

However, I hate the fact that I cannot refer directly to the reams of published scientific evidence that support using supplements to treat diseases. If you write for nutritional supplement companies you will face this frustration as well. And trying to optimize copy for search engines only adds to this frustration.

But as I described here, there are ways to stay FDA compliant and get some of the message out. If you’re looking for an area to make your mark as a copywriter, it’s an industry full of companies with excellent products desperately looking for good SEO copywriters. Particularly ones who have some understanding of FDA restrictions and can work within them.

If you write for nutritional supplement companies and would like more clarification on the FDA regulations, I’ve put together a bunch of good FDA resources on my website.


Author of the ebook, How To Write Irresistible Copy For Nutritional Supplements, Sarah Clachar specializes in writing for natural health products. She has written for companies both large and small, B2B as well as B2C. For copywriters interested in learning more about getting into health copywriting, Sarah offers a free 14-day e-course, “How To Become A Freelance Health Copywriter.” In this course, Heather Lloyd Martin’s SEO copywriting course is one of the courses she most highly recommends to aspiring health copywriters. When she’s not writing for her clients, Sarah can be found with her husband and two children mountain biking, skiing and working on their small farm in the hills of northern New England.



photo thanks to Ephermeral Scraps





13 replies
  1. Sarah says:

    Craig, I agree. One of my biggest frustrations – especially after reading dozens of studies that say just the opposite. However, it’s a compromise that protected the nutritional supplement industry from being shut down in many ways. So for now we work with it. Interesting to note, a few supreme court cases have been eating away at this law on freedom of speech grounds.

  2. craig wright says:

    I worry about the influence of drug companies. I read about kids in American schools being put on anti-depressants because they are badly behaved…that’s a bit too one flew over the cuckoo’s nest for my liking.

    It just doesn’t make sense. I took various drugs to try and stop a recurring cold sore and they all failed. I used raw garlic and it cleared it up and it never came back again. Is garlic a drug? No. Did it cure? Yes. How would they explain that?

  3. Sarah says:

    Craig, not to distract too much from the topic at hand . . . I’ve seen supplements cure cancer, MS and allergies.

    Best cure for this crazy legislation is education. And then as SEO copywriters, we can encourage our clients to develop info/edu websites or content archives that work within the two-click rule structure.

    The two-click rule gives us some flexibility in discussing the terrific research behind botanical and nutritional cures. It allows us to discuss ingredients and their role in helping with disease as long as we stay clear of mentioning the branded product.

  4. Aaron Hoos says:

    Thanks for the blog post! I write in a different field (financial and real estate) and face similar regulations from different regulating bodies. :)

    These regulating bodies might have consumer’s best interests at heart but it makes things challenging for us writers, particularly since prospects are searching for specific words that we can no longer use.

    It makes me wonder if there is a burgeoning opportunity for a new type of “bridge” content, almost like your 2-clicks-away idea but in reverse. In your example, perhaps there is a legal way to discuss disease and nutritional supplements and THEN drive prospects to your customer’s sales pages. It adds an extra layer to the sales funnel but it might solve the challenge you and I (and our copywriting peers) face.

  5. Sarah says:

    Interesting to hear about similar challenges in another area. Indeed, that’s exactly what works here. In fact, it opens up a whole new demand for good SEO content writing as part of the extended sales funnel. Have you used this in real estate copy?

  6. Inge Papp says:

    This is a fascinating post, Sarah, and one that I believe many young copywriters should read! One of the scary things about writing for the holistic or natural medicine industry is that you unearth a lot of research that flies in the face of conventional wisdom regarding diseases and their cures. Thanks for bringing this issue to light :)

  7. Sarah says:

    Inge, you’re right. Over and over again I’ve helped family and friends with information that their doctor’s have no clue about. I love this work because I learn so much useful information.
    Not to sound like a broken record – however – it’s very frustrating to be hampered in sharing this info with people who are desperately looking for it (your market) that’s why it’s so important to find strategic ways – like the 2-click rule – to try and share it. As well as develop creative ways to hit on people’s core desires that allow you to speak to them without mentioning disease claims. Thanks for commenting!

  8. Mollie Reidland says:

    “As a health writer of close to 15 years, I know how frustrating chronic yeast infections are.”

    As a user of the English language for 30 years, I know how frustrating non sequiturs can be.

  9. Sarah says:


    Believe me – if you’ve pored over testimonials of women struggling to find relief . . . if you’ve interviewed health practitioners describing how ineffective standard treatments are . . . if you looked at the stat’s of how often yeast infections recur and turn into more serious conditions . . . you wouldn’t see that as a non sequitur. My experience as a health writer has given me a window into many experiences I hope to never have.

  10. Norman Kerman says:

    Yes, it’s true. I have been manufacturing health products since 5 years. I had hired a writer for website content writing, and she just provided pieces of crap. Ranking of my website started falling due to poor and spammy content. I became helpless, as I knew nothing about copywriting. I came across Your Copywriter’s website, and had talked with Michael Jones. He is a wonderful natural health copywriter, and has been working for my website for over 2 years. My site is now performing well on search engines, and I am also getting good leads.


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  1. […] Supplements were distinguished from drugs by defining drugs as the only substances that can cure, prevent or alleviate the symptoms of a disease. Despite literally hundreds of thousands of published studies showing they help with diseases, supplements can only be discussed with reference to how they support a normal, healthy structure or function in the body.1 […]

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