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MARKETING OPINION BLOG                                                      Volume 2, Issue 3, June 2009


                                                                        Cheerios is…clinically proven to lower cholesterol. A
     Cheeri-Oh-No’s:                                                    clinical study showed that eating two 1.5 cup servings
                                                                        daily of Cheerios cereal reduced bad cholesterol when

      Marketing Misleading Health Claims                                eaten as part of a diet low in saturated fat and
                                                                        cholesterol. (Reference:
                   By: Latesha Richards                                 http://www.fiercebiotech.com/press-releases/fda-
                                                                        warning-letter-general-mills)
                    Date: June 18, 2009




A
            s a consumer and a huge fan of the
            cereal, I will continue to purchase my
            favorite Cheerios® brand on the
market, Honey Nut Cheerios®, because of its
great taste, crunchiness, easy to eat factor and its
role as part of an overall healthy diet rich in
whole-grains. But as a marketer, I take issue
with a healthy food being marketed as a drug that
you can access in the cereal aisle of every
supermarket and purchase for just about $5 a
                                                                 For a long time, General Mills has maintained
box. General Mills crossed the line from
                                                                 consistent advertising on the front panel of the
marketing a high-fiber/whole grain cereal to
                                                                 cereal box that a serving of Cheerios® together
marketing an unapproved drug. Marketers
                                                                 with exercise and a diet high in fruits, vegetables
understand that in a tough economy, advertising
                                                                 and grains and low in saturated fat and
new information and findings are the keys to
                                                                 cholesterol may reduce the risk of heart disease.
winning in the game of marketing. When it
                                                                 But the FDA has shed light on a claim made that
comes to health and educating the public, the
                                                                 essentially makes a different argument about the
rules are the rules, and Cheerios® clearly
                                                                 health benefits of the cereal. Let’s look more
violated them.
                                                                 closely at the controversial claim that the FDA
        Excerpt from General Mills’ Warning letter:              took issue with. In the past 2 years, General

        -   “You can lower your cholesterol 4% in 6 weeks”       Mills claimed that with Cheerios® “you can
                                                                 lower your cholesterol by 4% in 6 weeks.”
        “Did you know that in just 6 weeks Cheerios can
        reduce bad cholesterol by an average of 4 percent?       Firstly, there is nothing therapeutically different

                                                             1
MARKETING OPINION BLOG                                                          Volume 2, Issue 3, June 2009


about Cheerios® compared to some other whole-                        heart health, why then is a cereal maker making
grain/fiber-based cereals currently on the market                    a claim that it can lower cholesterol? A couple
such as Quaker Oatmeal®, Post’s Shredded                             of questions come to mind when thinking about
Wheat®, or even Kellogg’s Healthy Choice Low                         this – is eating a cereal more effective at
Fat Granola®, just to name a few. They all                           lowering cholesterol than taking an approved
contain whole grain oats and soluble fiber, which                    drug for the disease, a healthy diet and regular
has been said to help lower blood LDL                                exercise? Would a sufferer of high cholesterol
cholesterol and thus reducing the risk of                            think that he/she would be cured of their illness
coronary heart disease. Unless you were eating                       by just eating a few bowls of Cheerios® every
high fat and cholesterol foods for a long time and                   day without a healthy diet and no exercise? That
then suddenly modified to a diet high in soluble                     claim would be quite misleading to a consumer
fiber/whole grains in the morning, any of those                      attempting to make a diet adjustment.
whole grain cereals would have likely exhibited
the same cholesterol-lowering effects.

Secondly, I ponder on the question of why
General Mills is likening Cheerios® to an FDA-
approved, clinically proven drug? The drug
makers of Lipitor® and Crestor® can make
cholesterol-lowering claims because they have
been authorized to do so. Directly beneath the
Crestor® health claims on its website, the drug
maker makes a disclaimer about cholesterol-
lowering medication:                                                 The FDA seemed to miss another version of the
       “To get the greatest benefit from a cholesterol               Cheerios® front panel label which claims
       medication, you should still follow a diet low in             “Cheerios® helps lower cholesterol 10% in one
       saturated fats and cholesterol and exercise regularly.”
                                                                     month.” Not only is this information misleading,
       (Reference: www.crestor.com)
                                                                     but it seems to contradict the reduction in
If a clinically proven, FDA-approved drug is                         cholesterol by 4% in 6 weeks statement under
making this claim about overall cholesterol and                      FDA scrutiny. General Mills seems to be

                                                                 2
MARKETING OPINION BLOG                                                            Volume 2, Issue 3, June 2009


hooked on making specific claims that                                         that cause it to be a drug…” (Reference:
                                                                              http://www.fiercebiotech.com/press-releases/fda-
Cheerios® itself is responsible for lowering
                                                                              warning-letter-general-mills)
cholesterol when in fact whole grains and high
fiber as part of an overall healthy diet package                              I doubt that General Mills purposely

containing more fruits, vegetables, grains and                        intended to market Cheerios® as a drug,

lower saturated fat and cholesterol that makes the                    knowing that any clinical data provided to

difference.                                                           support such a therapeutic claim for a food
                                                                      product would by no means be convincing to the
The second half of the claim states “…A clinical                      FDA. As probably the most known maker of
study showed that eating two 1.5 cup servings                         cereal, General Mills wanted to simply
daily of Cheerios® cereal reduced bad                                 strengthen their position as a market leader in
cholesterol when eaten as part of a diet low in                       whole-grain cereals such as Cheerios®, Total®
saturated fat and cholesterol.” I agree with the                      and Wheaties® in order to gain competitive
FDA about the wording and placement of the                            edge. But it can’t only be about increased sales.
claim on the package design. The claim is                             It is like a TV advertisement pitching a more
prominently seen in a banner on the front panel                       superior level of crash safety of a certain brand
of the packaging written in big, bold font. The                       of car, over a competing automobile brand that
clinical study that the claim refers to is on the                     has been also rated superior in crash safety.
back of the Cheerios® box, which makes the                            Does this mean that I should not buy the
claim look a separate argument altogether. Did                        competing car because it appears to be less safe
General Mills realistically think that the claim                      than the car being advertised? No one is saying
would have gone unseen for much longer? Their                         that their clinical studies are flawed, not true or
warning letter was inevitable.                                        that evidence to support their claim was missing.
        The FDA concludes in the warning letter that:                 But this type of marketing Cheerios® was
                                                                      involved in is misleading and is a lesson that all
        “[This] claim indicate[s] that Cheerios is intended for
        use in lowering cholesterol, and therefore in                 food makers, nutritional supplement, natural
        preventing, mitigating and treating the disease               product manufacturers and ingredient suppliers
        hypercholesterolemia…[and] coronary heart disease
                                                                      should learn from. At the end of the day this will
        through lowering total and “bad” LDL cholesterol.
        Another excerpt of the letter states that the FDA             all come down to appropriate wording for the
        “determined that [General Mills’] Cheerios Toasted            cereal maker.
        Whole Grain Oat Cereal is promoted for conditions
                                                                  3
MARKETING OPINION BLOG                                           Volume 2, Issue 3, June 2009


         General Mills needs to be consistent with
their messaging across their packaging and
website. They need to stick with the general
claim that diets rich in whole grain foods and
fiber-containing fruits and vegetables and low in
saturated fats and cholesterol can reduce the risk
of heart disease, and not single out whole grain
foods, specifically Cheerios® as the cause for
reduction. For more than 2 years, General Mills
was able to make had it pretty easy. Now we see
a new and more aggressive FDA. Thanks to
President Obama’s appointment of Margaret
Hamburg as the new head of FDA, industries
other than pharmaceuticals will be upheld to
their highest ethical standards. I wonder who
will be next on the FDA hot seat?

The author, Latesha Richards, is Marketing Coordinator for
 utraceutical Medical Research, LLC. The statements made
above with regard to General Mills and Cheerios® does not
represent the beliefs or opinions of utraceutical Medical
Research, LLC.




                                                             4

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Cheerios Opinion Blog Nmr News June 2009

  • 1. MARKETING OPINION BLOG Volume 2, Issue 3, June 2009 Cheerios is…clinically proven to lower cholesterol. A Cheeri-Oh-No’s: clinical study showed that eating two 1.5 cup servings daily of Cheerios cereal reduced bad cholesterol when Marketing Misleading Health Claims eaten as part of a diet low in saturated fat and cholesterol. (Reference: By: Latesha Richards http://www.fiercebiotech.com/press-releases/fda- warning-letter-general-mills) Date: June 18, 2009 A s a consumer and a huge fan of the cereal, I will continue to purchase my favorite Cheerios® brand on the market, Honey Nut Cheerios®, because of its great taste, crunchiness, easy to eat factor and its role as part of an overall healthy diet rich in whole-grains. But as a marketer, I take issue with a healthy food being marketed as a drug that you can access in the cereal aisle of every supermarket and purchase for just about $5 a For a long time, General Mills has maintained box. General Mills crossed the line from consistent advertising on the front panel of the marketing a high-fiber/whole grain cereal to cereal box that a serving of Cheerios® together marketing an unapproved drug. Marketers with exercise and a diet high in fruits, vegetables understand that in a tough economy, advertising and grains and low in saturated fat and new information and findings are the keys to cholesterol may reduce the risk of heart disease. winning in the game of marketing. When it But the FDA has shed light on a claim made that comes to health and educating the public, the essentially makes a different argument about the rules are the rules, and Cheerios® clearly health benefits of the cereal. Let’s look more violated them. closely at the controversial claim that the FDA Excerpt from General Mills’ Warning letter: took issue with. In the past 2 years, General - “You can lower your cholesterol 4% in 6 weeks” Mills claimed that with Cheerios® “you can lower your cholesterol by 4% in 6 weeks.” “Did you know that in just 6 weeks Cheerios can reduce bad cholesterol by an average of 4 percent? Firstly, there is nothing therapeutically different 1
  • 2. MARKETING OPINION BLOG Volume 2, Issue 3, June 2009 about Cheerios® compared to some other whole- heart health, why then is a cereal maker making grain/fiber-based cereals currently on the market a claim that it can lower cholesterol? A couple such as Quaker Oatmeal®, Post’s Shredded of questions come to mind when thinking about Wheat®, or even Kellogg’s Healthy Choice Low this – is eating a cereal more effective at Fat Granola®, just to name a few. They all lowering cholesterol than taking an approved contain whole grain oats and soluble fiber, which drug for the disease, a healthy diet and regular has been said to help lower blood LDL exercise? Would a sufferer of high cholesterol cholesterol and thus reducing the risk of think that he/she would be cured of their illness coronary heart disease. Unless you were eating by just eating a few bowls of Cheerios® every high fat and cholesterol foods for a long time and day without a healthy diet and no exercise? That then suddenly modified to a diet high in soluble claim would be quite misleading to a consumer fiber/whole grains in the morning, any of those attempting to make a diet adjustment. whole grain cereals would have likely exhibited the same cholesterol-lowering effects. Secondly, I ponder on the question of why General Mills is likening Cheerios® to an FDA- approved, clinically proven drug? The drug makers of Lipitor® and Crestor® can make cholesterol-lowering claims because they have been authorized to do so. Directly beneath the Crestor® health claims on its website, the drug maker makes a disclaimer about cholesterol- lowering medication: The FDA seemed to miss another version of the “To get the greatest benefit from a cholesterol Cheerios® front panel label which claims medication, you should still follow a diet low in “Cheerios® helps lower cholesterol 10% in one saturated fats and cholesterol and exercise regularly.” month.” Not only is this information misleading, (Reference: www.crestor.com) but it seems to contradict the reduction in If a clinically proven, FDA-approved drug is cholesterol by 4% in 6 weeks statement under making this claim about overall cholesterol and FDA scrutiny. General Mills seems to be 2
  • 3. MARKETING OPINION BLOG Volume 2, Issue 3, June 2009 hooked on making specific claims that that cause it to be a drug…” (Reference: http://www.fiercebiotech.com/press-releases/fda- Cheerios® itself is responsible for lowering warning-letter-general-mills) cholesterol when in fact whole grains and high fiber as part of an overall healthy diet package I doubt that General Mills purposely containing more fruits, vegetables, grains and intended to market Cheerios® as a drug, lower saturated fat and cholesterol that makes the knowing that any clinical data provided to difference. support such a therapeutic claim for a food product would by no means be convincing to the The second half of the claim states “…A clinical FDA. As probably the most known maker of study showed that eating two 1.5 cup servings cereal, General Mills wanted to simply daily of Cheerios® cereal reduced bad strengthen their position as a market leader in cholesterol when eaten as part of a diet low in whole-grain cereals such as Cheerios®, Total® saturated fat and cholesterol.” I agree with the and Wheaties® in order to gain competitive FDA about the wording and placement of the edge. But it can’t only be about increased sales. claim on the package design. The claim is It is like a TV advertisement pitching a more prominently seen in a banner on the front panel superior level of crash safety of a certain brand of the packaging written in big, bold font. The of car, over a competing automobile brand that clinical study that the claim refers to is on the has been also rated superior in crash safety. back of the Cheerios® box, which makes the Does this mean that I should not buy the claim look a separate argument altogether. Did competing car because it appears to be less safe General Mills realistically think that the claim than the car being advertised? No one is saying would have gone unseen for much longer? Their that their clinical studies are flawed, not true or warning letter was inevitable. that evidence to support their claim was missing. The FDA concludes in the warning letter that: But this type of marketing Cheerios® was involved in is misleading and is a lesson that all “[This] claim indicate[s] that Cheerios is intended for use in lowering cholesterol, and therefore in food makers, nutritional supplement, natural preventing, mitigating and treating the disease product manufacturers and ingredient suppliers hypercholesterolemia…[and] coronary heart disease should learn from. At the end of the day this will through lowering total and “bad” LDL cholesterol. Another excerpt of the letter states that the FDA all come down to appropriate wording for the “determined that [General Mills’] Cheerios Toasted cereal maker. Whole Grain Oat Cereal is promoted for conditions 3
  • 4. MARKETING OPINION BLOG Volume 2, Issue 3, June 2009 General Mills needs to be consistent with their messaging across their packaging and website. They need to stick with the general claim that diets rich in whole grain foods and fiber-containing fruits and vegetables and low in saturated fats and cholesterol can reduce the risk of heart disease, and not single out whole grain foods, specifically Cheerios® as the cause for reduction. For more than 2 years, General Mills was able to make had it pretty easy. Now we see a new and more aggressive FDA. Thanks to President Obama’s appointment of Margaret Hamburg as the new head of FDA, industries other than pharmaceuticals will be upheld to their highest ethical standards. I wonder who will be next on the FDA hot seat? The author, Latesha Richards, is Marketing Coordinator for utraceutical Medical Research, LLC. The statements made above with regard to General Mills and Cheerios® does not represent the beliefs or opinions of utraceutical Medical Research, LLC. 4