UNITED STATES OF AMERICA 

Federal Trade Commission 

WASHINGTON, D.C. 20580 

April 24, 2020 

Via Electronic Mail 

doTERRA International, LLC 

c/o Mark A. Wolfert, General Counsel 

389 South 1300 West 

Pleasant Grove, Utah 84062 

Warning Regarding Health and Earnings Claims Related to Coronavirus 

Disease 2019 (COVID-19) 

Dear Mr. Wolfert, 

FTC staff has reviewed social media posts made by doTERRA International, LLC 

(“doTERRA”) business opportunity participants or representatives that unlawfully advertise that 

certain products treat or prevent Coronavirus Disease 2019 (COVID-19) and misrepresent that 

consumers who become doTERRA business opportunity participants are likely to earn 

substantial income. This letter is to provide you with information about laws and regulations 

enforced by the Federal Trade Commission (“FTC”) that may bear upon your business activities, 

including the activities of your business opportunity participants and representatives. 

Some examples of Coronavirus prevention or treatment claims made by your business 

opportunity participants or representatives include: 

 “... If interested to learn more or obtain oils or rollers Let me know A little extra 

protection can help #doterra #NursesCOVID19 #Dialysis #ImmunityBoosters 

#ImproveRespiratoryFunction” The text accompanied an image titled “Grocery 

Store Clerks, Truck Drivers, Medical Responders, Teachers, Small Businesses, 

Mamas, and EVERYONE else” followed by a message composed of text and 

images of doTERRA-brand essential oil bottles. 

 An image of doTERRA-brand peppermint and lemon essential oil bottles, 

accompanied by the hashtags “#covid #prevention.” 

 “This is to inform us all that the pH for corona virus varies from 5.5 to 8.5.... All 

we need to do, to beat corona virus, we need to take more of an alkaline foods that 

are above the above pH level of the Virus. Some of which are: Lemon... Lime... 

Tangerine... Orange... #covid... #doterra #doterraph #doterraphillapines.” The 

text accompanied an image of lemon, lime, tangerine, wild orange, and ginger 

doTERRA-brand essential oil bottles. 
 

 

Some examples of earnings claims made by your business opportunity participants or 

representatives include: 

 “For those of you working from home now, who says you ever have to go back? 

With a little education and a lot of uplifting support... you can take your health 

and your career future into your own hands.” 

 “Need to make extra money? Find it difficult to pay your bills? Were you laid off/ 

#fired? Be your own Boss w/doTERRA essential oils. Msg me to achieve 

financial independence #laidoff #unemployed #cantpaymybills #cantpaymyrent 

#student #sales #sidehustle #makemoney #stayathomemom.” 

It is unlawful under the FTC Act, 15 U.S.C. § 41 et seq., to advertise that a product can 

prevent, treat, or cure human disease unless you possess competent and reliable scientific 

evidence, including, when appropriate, well-controlled human clinical studies, substantiating that 

the claims are true at the time they are made. For COVID-19, no such study is currently known 

to exist for the products identified above. Thus, any coronavirus-related prevention or treatment 

claims regarding such products are not supported by competent and reliable scientific evidence. 

You must immediately cease making all such claims. 

Additionally, representations about a business opportunity, including earnings claims, 

violate Section 5 of the FTC Act, 15 U.S.C. § 41 et seq., if they are false, misleading, or 

unsubstantiated and material to consumers. Express and implied earnings claims must be truthful 

and non-misleading to avoid being deceptive, which means that claims about the potential to 

achieve a wealthy lifestyle, career-level income, or significant income are false or misleading if 

business opportunity participants generally do not achieve such results. Even truthful 

testimonials from participants who do earn significant income or more will likely be misleading 

unless the advertising also makes clear the amount earned or lost by most participants. Your 

business opportunity participants and representatives must immediately cease making all express 

and implied earnings claims that would be false or misleading to current or prospective 

participants. 

You are responsible for the claims of your business opportunity participants and 

representatives. As the FTC stated in the January 2019 Business Guidance Concerning MultiLevel Marketing, the compensation structure of a Multi-Level Marketing entity (“MLM”) may 

create incentives for its participants to make certain representations to current or prospective 

participants. “As a consequence, an MLM should (i) direct its participants not to make false, 

misleading, or unsubstantiated representations and (ii) monitor its participants so they don’t 

make false, misleading, or unsubstantiated representations.” 

You are advised to review all claims relating to your products and business opportunity 

and immediately cease, and require your business opportunity participants and representatives to 

cease, making claims that are not supported by the evidence or substantiation described above. 

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Within 48 hours, please send reply via email to COVID-19-Task-Force@ftc.gov 

describing the specific actions you have taken to address the FTC’s concerns. If you have any 

questions regarding compliance with the FTC Act, please contact us at COVID-19-TaskForce@ftc.gov. 

 Sincerely,

 Federal Trade Commission Staff 

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