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





Jill Whalen on SEO: then & now

Jill Whalen will always have a special place in my heart. Back in the day, we had a lot of “firsts” together.  We spoke at  Search Engine Strategies for the first time together. We presented at our first international conference together.  And we created RankWrite together, the first newsletter that discussed SEO and copywriting.

Jill was also featured in our “SEO women” series as one of the first-generation woman pioneers who helped build and define the SEO and search industry.

Here,  Jill shares about her path to becoming a leader in the SEO copywriting profession, answers our questions about Google’s latest updates, and discusses her perception of the SEO and search industry as a whole…including why truly good SEO copywriters are a rare breed, indeed.

Enjoy! – Heather

Q:  As one of the first wave of women who pioneered SEO, could you share with us your journey into that wild west world?

That’ll take us waaaaaay back to the early 1990’s when my kids were little and I first got online with a 2400 baud modem!

I got interested in IRC chat and created a parenting chat channel. By 1993 I taught myself HTML and developed a parenting website to go along with the chat room.

I was determined to figure out how to get that site found in the search engines of the day, i.e., Lycos, Excite, Webcrawler, so the same way that I taught myself HTML I analyzed what made certain websites rank for certain keywords and others not.

  • Discovering “SEO” – before it was “SEO”

It was pretty obvious at the time that it was the words on the page that would make the most difference. If you wanted to show up for a keyword phrase such as “parenting chat” then you needed to show that your site was obviously focused on being a place where parents could chat. Pretty obvious, but funny how others just weren’t thinking in those terms.

Eventually I started offering to design websites for some of the parents I had met online in my chatroom, and that gave me the opportunity to play with my new found SEO knowledge (it of course wasn’t called “SEO” yet).

Others had started to figure out the whole words on the page “trick” but instead of just making their pages relevant to what they wanted to rank for, many simply hid the words at the bottom of the page or with a font in the same color as the background of the page.  (I laugh when I still see this going on today, as if these people think they were the first to think of something so “clever”!)

  • The power of great copywriting

I went the opposite route for my clients and hired people far better at copywriting than I was, to describe what my clients offered in a way that would entice people to want to purchase from them. (That’s how Heather and I hooked up back in the late 90’s.)

And suddenly the SEO copywriting industry was born!

I found that the hard part of SEO was finding great writers. But once you found them, it was simple enough for them to understand the whole process of making sure they used keywords within their great writing.

Today I find that while great copywriting is still the number 1 thing you can do for a website, and I still recommend it for most sites, I focus my own energies on diagnosing technical issues that can hurt a website’s ability to gain the search engine traffic they deserve.

  • On search engine friendly website design

Website designs have become so complicated, and surprisingly too many developers still don’t understand how to create a truly search engine friendly site.

In addition, I love using Google Analytics (GA) to figure out why a website has suddenly lost a good portion of their search engine visitors. GA is so powerful these days, and if you know what you’re doing, it’s almost like being able to go back in time to see what was previously happening and then comparing it to what is happening now.

Q:  So what is your take on Google’s data encryption? How do you see it affecting keyword research?

Sadly, Google encrypting the searches of people who are logged into Google products such as Gmail and Google Analytics has meant that website owners have lost a lot of keyword data that we used to have regarding who visited our sites.

It shouldn’t affect keyword research as Google’s keyword research tool still provides the same data, but it will affect being able to effectively measure our success. It’s hard to know if the keywords you optimized for are bringing you traffic if you can’t see exactly what those keywords are in your analytics.

I actually just wrote a post about this subject: Measuring Natural Keyword Traffic in the Age of (NotProvided) Secure Search.

Q:  What are your thoughts about Google Search Plus?

It’s good and bad.

Sometimes I like it when I’m looking for a past article that someone in my online social circle has written. And I also like that it’s helping SEOs to *finally* agree that rankings are no longer possible as a way to accurately measure SEO success since they’re different for everyone. (That’s something I’ve been saying for years, but SPYW has made it all that much clearer.)

To go along with that I like that it should help to get search marketers focused on making their pages better overall, rather than being concerned with just a couple of keyword phrases and where their page shows up.

On the other hand, as a user/searcher it’s often annoying as I don’t always want to see what my friends have recommended! (You can hit the “non-personalized results” button, which does help.)

As to how it will affect SEO overall, it’s much too soon to say. They’re still tweaking it a lot and have already made Google+ results not quite as heavily featured as it was at first.

I’d recommend keeping an eye on it, but don’t make any major changes in the way you do business just because of it. You should probably have a Google+ account and filled out profile, though, if for no other reason than to get Google Author status which is an amazing perk for anyone who puts content online.

Q:  What is your take on Google’s “over optimization” penalty?

Aside from the fact that it’s impossible to “over-optimize” anything (because to optimize is to make perfect and you can’t go beyond perfect!) it’s likely just Google propaganda to scare dumb SEOS and web spammers.

But if it is indeed a real thing (and I hope it is) then it’s all a step in the right direction for Google. I’ve always found it annoying that SEO in all the right places could often beat out sites that were actually much better, but didn’t know anything about SEO. You shouldn’t be able to stick an extra keyword in a Title tag of a crappy site and have it beat out a great site!

So if it’s indeed something Google’s working on or implementing, it will finally make what I have been teaching in SEO for over 10 years to be true! (To be clear, what I’ve been saying and teaching did always work, but it was and is a long-term process which could sometimes get temporarily beat out by silly SEO parlour tricks.)

I’ve always said that the better Google gets as a search engine, the better the sites who’ve used my SEO methods would do. And they are! Hard work and good marketing should pay off even better if Google is serious about their spam fighting.

Q:  What would you say are the most important factors influencing SEO now?

This is a difficult one to answer as it’s different for every site. There’s certainly no magic formula or something that will work for every site.

  • Site architecture

That said, I find that having the right site architecture can make a huge difference for most websites. That is, creating a great hierarchy for your site so that the most important top level category pages are linked to from your global navigation, and then those top level pages each link into their own little subset of pages within their sub-category.

This pushes or funnels your internal link popularity properly throughout your site so that your main pages can be optimized for the more competitive phrases and your deeper pages for more long-tail phrases.

  • Technical, duplicate content issues

Another key factor influencing SEO is fixing any technical duplicate content issues. And by that I don’t mean duplicate content in the sense of someone posting someone else’s article on their site, but more the issues that can be created by some content management systems when they create multiple URLs for the same content.

Cleaning up those issues via rel=canonical or other means can make a huge difference to a site’s ability to get targeted search engine traffic.

  • Content marketing

And because nearly every industry has become so competitive online, it’s critical for people to market their websites via a blog and/or email newsletter or some other outlet that can showcase the company’s areas of expertise on a regular basis.

This will help to bring new people to the website who may still be in the research phase, but who may be ready to buy at some point in the future.

Q:  You’ve been in the SEO industry since the (pre-) beginning. What’s your overall impression of the profession, from where it started to where it’s going?

I have both good and bad impressions of the SEO industry.

I know and have met tons of people who truly get SEO and want to make a difference for the companies they work for. Unfortunately, I believe they are still few and far between.

It’s too easy to talk a good game about SEO without really knowing what you’re doing. And many companies are getting burned by them.

While many scammy SEO companies exist, clients have to take responsibility for doing their due diligence before hiring one. It’s often a case of the quick fix mentality, which clients often have. They want what they want, and they want it yesterday.

While a professional SEO consultant will set realistic expectations, often it’s not what the client wants to hear, so they’ll find an SEO company who will tell them what they do want to hear. In which case, they get what they deserve!

I kind of hate to say this, but with SEO being so hard to pinpoint these days (in terms of how to do it), I think businesses new to website marketing may want to start out with PPC first to see how their site performs overall. That way they can learn what works and what doesn’t.

Once they are making some profit through that marketing channel, then they can start branching out into SEO. It will be much easier at that point, because they’ll have hard data that they can use to optimize for the natural listings.

Overall, I feel that the better Google gets at fighting web spam, the better our industry will be. If spammy stuff simply doesn’t work anymore, those bad companies should eventually die out. And the sooner that happens, the better!

About Jill Whalen

Jill is the CEO of High Rankings and has been in SEO since its pre-beginnings, circa early 1990’s.She is a prolific writer and contributes regularly to Search Engine Land and Talent Zoo. Jill also founded and runs the High Rankings Newsletter, and just recently started an online forum for those interested in Google Analytics, specifically its custom reports, at Custom Report Sharing. You can contact Jill via her High Rankings website, and find her on Twitter at @JillWhalen.


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photo thanks to aussiegall




SEO content marketing roundup, week ending April 20th

Maybe it’s due to the tax season, but there seems to be a lot of number crunching going on in this week’s latest and greatest web writing news.  From content marketers trying to make sense of data and social media marketers measuring returns on relationships, to the SEO and search community analyzing the relative impact of social influences, valuation is the common denominator.  Here’s the tally of this week’s selections:

Content Marketing:

Great read at Design Damage about achieving long-term online marketing success, and a smart post at Eisenberg & Associates exploring the value of content marketing.

Seth Godin addresses the “economies of small,” and “tiny media” (the four horsemen of media).

HubSpot posts Excel tricks for crunching tons of marketing data, as well as an (“inbound now’) interview with Joe Pulizzi about all things content.

Content Marketing Institute posts a two-part series on content marketing analytics, the first about what to do with all those numbers and the second about turning analytics into actionable tasks.

The brave and bumpy path to exceptional content is posted at Shelly Bowen’s site (pybop), while Copyblogger posts how brevity can sometimes be bad for your content.

Hugo Guzman discusses the Johari Window concept as a way to understand your marketing, and HubSpot posts a video interview with Gary Vaynerchuk on “context marketing.”

Sonia Simone posts how to consistently attract high-quality traffic to your site at Copyblogger, and Frank Reed posts the many factors that make up internet marketing at Marketing Pilgrim.

Patsi Krakoff (of “the Blog Squad”) posts how to connect the dots to drive content marketing results at Writing on the Web, and Brian Tarcy offers five tips for better business storytelling via HubSpot.

The fundamentals of starting a company blog are at {grow}, and brand expert Jim Joseph shares tips to win customer loyalty at PR Web.

An interesting interview with Hugh MacLeod, discussing the infinite market for something to believe in, is posted at Copyblogger.

Content Marketing Institute offers a step-by-step guide to the new LinkedIn company pages for content marketers, and Search Engine Journal posts free Google tools for generating great web content ideas.

Social Media Today posts thinking strategically about content curation, and a Mashable posts no less than 40 new digital media resources.

Finally, Marketing Sherpa’s inaugural Optimization Summit, June 1st – 3rd in Atlanta, is fast running out of room.  Those interested are urged to register soon!

SEO & Search:

Marylene Delbourg-Delphis authors a great piece about the real nature of SEO power words at her site, and Distilled’s Tom Critchlow shows “how to make SEO happen” at SEOmoz.

ClickThrough Marketing reveals the biggest search engine marketing spenders, and Forbes’ Jeff Bercovici reports that Demand Media shares have tanked as a result of Google’s Farmer/Panda update.

In a related post, Search Engine Land’s Matt McGee reports that Google has lowered the boom on eHow, and Pamela Parker reports that the big G is planning to distinguish poor quality landing pages from policy violations.

SEOptimise publishes 30+ resources for Google’s Farmer/Panda update, while DIY SEO gleans the opinions of 45 experts on the biggest mistakes that small businesses make with SEO and online marketing.

Smart guest post by Level 343’s Gabriella Sannino about the need for customized social media and SEO strategies is at Search Engine Journal, and Search Engine Watch posts a great piece on “granular” SEO analytics.

Michael Gray addresses steps to make your website look more brand-like to Google at his SEO blog, and Kimberly Castleberry shares Matt Cutts’ video addressing how to prove your content is original at her site.

Search Engine Land post discusses an “Outbrain” study showing that search drives both more and better traffic to content sites than does social media.

Rand Fishkin looks at detailed data about the relative influence of Facebook and Twitter on Google search rankings at SEOmoz: interesting!

Website Magazine posts an article on 2011 search marketing trends, while Marketing Sherpa discusses capturing future seasonal traffic lifts with four SEO factors.

Ann Smarty guest posts on how to highlight your brand’s name in Google Reader search results at Search Engine Journal, and Linkbuildr discusses tactics for keeping your link-building “fresh.”

SEOmoz’s Dr. Pete discusses eight “easy wins” for on-page SEO, and Search Engine Land offers six simple SEO tips for small businesses.

On a much more ambitious note, SEO Book discusses starting an SEO business, and Level 343 takes on writing for your website visitors.

Finally, SEOmoz announces Pro SEO Boston, scheduled for May 16th and 17th.

Social Media Marketing:

The Social CMO proposes a new measure of social media success, namely, return-on-relationship (ROR) rather than ROI.

How to optimize your brand’s Facebook page for search engines is addressed at Read Write Web (Biz), while All Facebook posts tips for using Facebook features to market your brand.

Top Rank’s Lee Odden posts understanding B2B social media via infographics, and Social Media Examiner cites a study showing that small businesses benefit most from social media.

Pure Driven discusses how to protect your company from “dysfunctional” social media strategies, and Social Marketing Forum posts a thoughtful piece about social media advertising.

iMedia Connection posts simple tips for Facebook and Twitter success, as well as 10 Facebook lessons learned from Apple vs. Google.

The book “Marketing lessons from the Grateful Dead” is discussed by Mack Collier, while Brian Solis announces that his Engage 2.0 in now online and available at bookstores.

Social Media Examiner posts how to use geolocation in your marketing initiatives as well as ways to use social media to sell successfully.

Mark Schaefer posts a video interview with Jay Baer at {grow} in which Baer shares his advice for those wanting to go into social media consulting.

Speaking of Jay Baer, he ponders if Twitter is massively overrated at Convince and Convert, while For Free Blog discusses what makes a great tweet.

Finally, Social Media Examiner headlines its weekly news with YouTube’s new YouTube Live streaming video feature.