The NAD concluded that the company lacked “competent and reliable scientific evidence” to support several marketing statements for the NAD+-based products.
The decision, prompted by a challenge from competitor Niagen Biosciences Inc., cited issues with the company’s substantiation for health, purity and ingredient content claims, influencer disclosures and review practices.
NAD finds no substantiation for NAD+ efficacy claims
NAD’s review focused on a range of express and implied claims made by Reus Research, including statements on product packaging, Amazon listings and TikTok promotions. At issue were ingredient content claims stating that the Cata-Kor NAD+ Core and Advanced products contain 250 mg and 500 mg of LipoNAD+, respectively.
Reus maintained that the stated weight includes the liposomal layer, but NAD determined this could mislead consumers without clarifying the context.
“Absent reliable consumer perception evidence,” NAD wrote in its decision, it found that consumers would expect the labeled quantity to refer solely to the amount of NAD+ itself. As reported in the case decision, the panel recommended that the claims be discontinued or clarified when made outside of the supplement facts panel.
NAD also determined that the purity claims implied the presence of “pure NAD+,” a characterization unsupported by the company’s own testing results, and recommended that these claims be modified or discontinued to avoid conveying a misleading level of ingredient purity.
NAD further noted that Reus had not submitted human clinical evidence showing that orally ingested liposomal NAD+ raises NAD+ levels in the body, citing that “there was no evidence in the record to support Reus’s health or establishment claims related to the NAD+ in its products and therefore recommended Reus discontinue the challenged health claims.”
In an advertiser’s statement, Reus said it “will comply with NAD’s recommendations” and voluntarily agreed to discontinue several comparative, origin and health-related claims.
Niagen: ‘A critical consumer-protection signal’
NutraIngredients spoke to Carlos Lopez, senior vice president and general counsel at Niagen Biosciences, who explained the NAD decision highlights a broader need for scientific rigor when marketing NAD+-related products.
“The National Advertising Division found no human clinical evidence that orally ingested NAD+—liposomal or otherwise—changes NAD+ levels in the body…because NAD+ itself is not orally bioavailable as an intact molecule,“ he said. ”[In contrast], the precursor nicotinamide riboside (NR) crosses directly into the cell and has been shown in multiple peer-reviewed human studies to increase NAD+ levels.”
“This is a critical consumer-protection signal for the entire category—not just one brand, [and] consumers should not have to decode complex biochemistry; advertisers must meet the competent-and-reliable scientific evidence standard before making efficacy claims,” he added.
Jennifer Adams, partner at Amin Wasserman Gurnani LLP and counsel for Niagen in the case, told NI that the ruling is a reminder that even well-known biological concepts require hard data to support consumer-facing health claims.
“This is an important cautionary tale of misleading consumers on highly scientific substantiation,” she said. “Unfortunately, the science isn’t there, and consumers do not have the expertise or tools to know this, [which] is exactly why NAD and FTC hold health claims to a higher standard.”
Cata-Kor’s response
In a statement, a Cata-Kor spokesperson told NI that the company “fully cooperated with the NAD review and has implemented updates to ensure that all product communications meet the highest standards of accuracy and compliance.”
“We view this process as a constructive step that helps strengthen consumer trust and reinforces our commitment to responsible, science-backed marketing,” the spokesperson said.
Cata-Kor emphasized its continued investment in scientific substantiation, noting that it has completed preclinical testing and is currently conducting a human clinical study on its Liposomal NAD+ formulation in partnership with KGK Science, a contract research organization.
A compliance wake-up call?
Commenting independently, Asa Waldstein, founder and principal at Apex Compliance, explained that the ruling serves as a critical reminder for brands using novel delivery systems, such as liposomes, to ensure their claims are supported by robust evidence.
“Companies making claims about their novel delivery systems should make their best reasonable effort to comply with DSHEA and GMP requirements, but this is not always straightforward when testing potency levels in liposomes, as surfactants and specific testing methods may be required,” Waldstein told NI.
He also pointed to NAD’s findings on review repurposing, in which reviews of a different nicotinamide riboside (NR) product appeared alongside those for the newer NAD+ products.
“In this Reus Research NAD case, it appears reviews and ratings from a different product, nicotinamide riboside, were combined with the ‘substantially different’ NAD+ product,” Waldstein said. “This type of practice may lead to litigation and other regulatory issues.”
On influencer marketing, minor interactions, such as “liking” a comment, can also carry regulatory risk.
“Small interactions with third-party reviews, both on websites and on social media, may be considered endorsements, which means the company has adopted the review into its marketing and is therefore fair game for enforcement,” Waldstein said.
He also anticipates that similar scrutiny will continue. “I expect NAD challenge cases to continue, especially in competitive ingredient categories like NR, where incumbents are eager to defend their science and industry positions,” he said.
