SHORT ANSWER
Everything a buyer can see, not just the product page. FDA’s warning letters cite product descriptions, bundled supplies, social posts, blog articles, customer reviews, and even metatags as evidence of intended use. A reviewer works surface by surface and asks one question of each: does this say or imply the product is for use in a person? This checklist walks those surfaces in the order reviewers read them.
This material is general educational information as of the “last reviewed” date. It is not legal advice and may not reflect later developments or facts specific to your business. Links are provided so readers can inspect the primary or official sources.
01 / HOW TO USE THIS
A list of surfaces, not a pass/fail rubric
Reviewers, whether at FDA, FTC, a payment provider, or a scanner like RUO Clear, read a storefront as one presentation. FDA’s regulation on intended use, 21 CFR § 201.128, points to labeling, advertising, written statements, and the circumstances of distribution together. The FTC’s net-impression standard does the same for advertising claims. So the review is not “is there a disclaimer” but “what does the whole site say.”
Each section below names a surface, gives a short checklist, and says in one line why that surface matters, citing the count of FDA letters in RUO Clear’s corpus of 185 peptide-related warning letters (2021 to July 2026) that used it as evidence. The counts reflect RUO Clear’s tagging, not FDA statistics. Every item is a recommended control: it describes what reviewers look at, not a rule that makes a site lawful when checked.
For each surface, note what was found, what was changed, and the date. That record is the evidence a provider can read later; the last section explains how RUO Clear structures it.
02 / NAMES AND SLUGS
Product names, slugs, collections, and categories
Why it matters: a name is the first claim a buyer reads, and both agencies count names toward the overall message. FDA quoted brand-equivalence phrasing in 45 letters and dose-in-name phrasing in 6, per RUO Clear’s tagging.
- Product titles that name an outcome (lean, burn, repair, sleep, growth) or a condition
- Titles or slugs that name an approved drug brand or say “same as”
- Dose, cycle, or protocol language in the name (“10mg weekly”, “stack”, “kit”)
- Collection and category names that group by body goal instead of by compound
- URL slugs and breadcrumbs that still carry an old outcome-based name
03 / DESCRIPTIONS
Descriptions, benefit bullets, and “research shows” copy
Why it matters: the product page is the surface FDA cited most often, in 19 letters. The quoted lines are almost always benefit statements: appetite, glucose, fat loss, recovery, cognition.
- Any sentence describing an effect in a body, a person, a patient, or a “test subject”
- Mechanism copy that ends in a human outcome (“activates GLP-1 receptors, reducing appetite”)
- “Clinical trials show” or “research suggests” framing attached to a product for sale
- Comparisons to prescription products by name or by implication
- Dosing, reconstitution, injection, or cycle instructions anywhere on the page
04 / IMAGERY
Photos, diagrams, icons, and video
Why it matters: the FTC evaluates images as part of net impression, and a picture can make a claim no sentence on the page makes.
- Injection, syringe, or body-part imagery on product or category pages
- Before/after photos, physique imagery, or transformation graphics
- Icons that signal outcomes (a flame for fat loss, a brain for focus, a scale)
- Video thumbnails and embedded clips that show administration or results
- Image alt text and file names that repeat outcome language
05 / BUNDLES AND SUPPLIES
Kits, cross-sells, and administration supplies
Why it matters: FDA cited bacteriostatic water, syringes, or needles sold alongside peptides in 15 letters. The Gram Peptides and USApeptide.com letters both list the supplies next to the peptides as part of the intended-use evidence.
- Bacteriostatic water, insulin syringes, alcohol swabs, or needles in the catalog
- “Frequently bought together” and cart cross-sells that assemble an injection kit
- Bundle or kit names that describe a regimen
- Reconstitution calculators or dosing tools linked from product pages
06 / REVIEWS AND TESTIMONIALS
Customer reviews, star ratings, and quoted results
Why it matters: FDA quoted customer testimonials as efficacy evidence in 7 letters, and the FTC treats a testimonial the seller publishes as a claim the seller makes.
- Review widgets that display outcome language (“lost 12 pounds”, “sleeping better”)
- Curated or featured reviews on product and home pages
- Star ratings on “effectiveness” or “results”
- Testimonials in email, ads, or social posts the store controls
- Any review the store solicited with an incentive that is not disclosed
08 / CHECKOUT AND ATTESTATION
Cart, checkout, terms of sale, and “I am a researcher” gates
Why it matters: FDA has quoted the boundary language sellers put at checkout and set it aside in the same paragraph. In RUO Clear’s corpus, 15 letters expressly disregard a research-use or not-for-human-consumption disclaimer. A checkbox is one more statement; it does not change what the product page says.
- Attestation checkboxes and their wording
- Terms of sale and the surfaces that link to them
- Whether checkout copy contradicts product copy (research-only at the cart, outcomes on the page)
- Buyer-control gates: what they actually restrict and what they record
- Order confirmation and shipping emails, which repeat product names and descriptions
09 / DISCLAIMER PLACEMENT
Where boundary language sits, and what it sits next to
Why it matters: the FTC’s guidance says a qualifying disclosure must be clear and conspicuous and cannot cure a claim it directly contradicts. A disclaimer in the footer does not qualify a headline three screens above it.
RUO Clear’s own marketing guide treats disclaimer placement as a recommended control with two tiers: a short boundary statement placed persistently and near calls to action, and a full limitation statement on its own page linked from the short one. The same structure works for a storefront.
- A short research-use statement in the persistent footer and near every add-to-cart action
- A full statement of what the products are and are not sold for, on its own page, linked from the short one
- Disclaimer text visible on the product page itself, not only in a tab or accordion
- No disclaimer sitting directly beside a sentence it contradicts
- The same boundary language on packaging images, if the site shows packaging
10 / METADATA AND SEARCH
Titles, meta descriptions, keywords, and structured data
Why it matters: FDA cited website metatags or search keywords as proof of intended use in 2 letters. Buyers do not see this layer, but reviewers and crawlers do.
- Page titles and meta descriptions that carry outcome or brand-equivalence language
- Legacy keyword lists and hidden text
- Structured data (product schema) with description fields written for ranking
- Paid-search ad copy and landing pages
- Sitemap entries for pages that were “removed” from navigation but still resolve
11 / POLICIES AND CONTACT
About, shipping, refund, privacy, and contact pages
Why it matters: a provider’s reviewer reads these pages to confirm the business is what the application says it is. FDA letters address the firm named on the site, at the address on the site.
- Business name, address, and contact details match the entity applying for processing
- Shipping and refund policies that do not describe personal use or consumption
- An about page that describes the business without outcome language
- Privacy policy that matches the data the site actually collects at checkout
- No “medical advice” or “consult your doctor before use” framing, which itself implies use
12 / RECORD WHAT CHANGED
Turn the review into evidence
A checklist completed in someone’s head is not evidence. For each surface, keep what was captured, what was found, which source the finding maps to, what was changed, and when. A provider reviewing an application can then see the before, the after, and the reasoning, instead of a clean site with no history.
That is the structure RUO Clear’s scan follows: it states its coverage, maps each finding to a source, and preserves versioned snapshots of the pages it captured. What it cannot see, it says it cannot see.
QUESTIONS
Related questions
If I fix everything on this list, is my site compliant?
The list describes what reviewers look at; it does not decide legal status. Intended use is a fact-specific question, and a provider makes its own decision. Working through the list removes the observable contradictions that reviewers cite most often.
Which surface should I fix first?
Product names and descriptions, because they are cited most often and every other surface repeats them: cart lines, confirmation emails, feeds, and ads all inherit the product title.
Do I need to delete old blog posts and social content?
Reviewers read content attributed to the store regardless of age. Whether to edit, archive, or remove is a judgment call; leaving it untouched while the product pages change creates the contradiction the letters describe.
Does RUO Clear check all of these surfaces?
A scan covers the public and connected content listed on the coverage page and says which pages were captured, blocked, or out of scope. Linked social accounts and private content are out of view unless connected.
SOURCES
Sources cited
Each source is listed with its class so government authority, agency guidance, enforcement examples, and private policy are never blended into one rule.
Objective intent shown by labeling, advertising, written statements, and circumstances of distribution.
Net impression including names and images; clear and conspicuous disclosures; a disclosure cannot cure a contradictory claim.
Product-page benefit language and bacteriostatic water listed beside peptides, with research-use labeling set aside.
Four boundary statements quoted and set aside; brand equivalence, dosing language, and syringes cited.
07 / BLOG, SOCIAL, AND LINKED ACCOUNTS
Content on the domain and content attributed to it
Why it matters: FDA cited Facebook in 12 letters, Instagram in 8, blog or educational articles in 8, and YouTube in 4. Social content attributed to the firm appears as a violation theory in 25 letters. A clean product page does not neutralize an old post.