Nutrition & Wellness - Overview
48% internal adoption, 8% governance -- essentially ungoverned. FTC advertising rules exist but are not AI-specific. Wellness apps ship AI as the product itself. When a supplement recommendation engine or fitness algorithm faces an FTC inquiry, the question is whether the company can reconstruct what it recommended and why.
48% internal adoption, 8% governance -- a 34-point gap and essentially ungoverned. The wellness industry ships AI as the product itself: supplement recommendation engines, fitness algorithms, meal planners, and health coaching bots are all consumer-facing outputs with direct health implications. FTC Act Section 5 applies to every AI-generated health claim. FDA DSHEA structure/function claim rules do not exempt algorithmic recommendations. FTC Endorsement Guides apply when AI generates testimonial-style content. When a recommendation engine suggests a supplement interaction that harms a consumer and the FTC inquires, the response requires the specific model, the data it used, and the guardrails that were in place. Most wellness companies cannot produce that reconstruction today. The regulatory surface is real. The governance infrastructure is absent.
This industry includes 2 segments in the Ontic governance matrix, spanning risk categories from Category 1 — Assistive through Category 1 — Assistive. AI adoption index: 5/5.
Nutrition & Wellness - Regulatory Landscape
The nutrition & wellness sector is subject to 8 regulatory frameworks and standards across its segments:
- App store policies
- COPPA (if under-13 users)
- FDA DSHEA (21 USC 343)
- FDA mobile medical app guidance (if health claims)
- FTC Act Sec. 5
- FTC Endorsement Guides
- NAD/NARB self-regulatory guidelines
- State consumer protection statutes
The specific frameworks that apply depend on the segment and scale of deployment. Cross-industry frameworks (GDPR, ISO 27001, EU AI Act) may apply in addition to sector-specific regulation.
Nutrition & Wellness - Nutrition & Supplements -- DTC Brand or Retailer
Risk Category: Category 1 — Assistive Scale: SMB Applicable Frameworks: FTC Act Sec. 5, FDA DSHEA (21 USC 343), NAD/NARB self-regulatory guidelines, State consumer protection statutes, FTC Endorsement Guides
Every AI-generated health claim is an FTC surface waiting to be examined.
The Governance Challenge
DTC supplement brands use AI to generate product descriptions, ingredient explainers, and customer-facing health content at volume. FDA DSHEA draws a hard line between structure/function claims and disease claims — and generative models do not know where that line is. When a model generates a claim that crosses it, the brand carries the liability. Most DTC operations have no mechanism to catch the violation before it reaches the customer.
Regulatory Application
FTC Act Section 5 prohibits deceptive health claims regardless of whether a human or model generated them. FDA DSHEA requires structure/function claims be truthful, non-misleading, and substantiated. NAD/NARB self-regulatory actions are increasing against AI-generated advertising. State consumer protection statutes add jurisdiction-specific exposure.
AI Deployment Environments
- Studio: Product description drafting | Ingredient research summarization | Customer FAQ generation
- Refinery: Health claims governance | Structure/function claim compliance | Disclaimers and required disclosures
Typical deployment path: Studio → Studio → Refinery
Evidence
- FTC averaged 20+ enforcement actions per year against supplement health claims (2022-2024)
- 48% of wellness companies use AI internally; 8% have any governance framework
- NAD/NARB referrals for AI-generated advertising claims began in 2024
Nutrition & Wellness - Wellness & Fitness -- Consumer Apps
Risk Category: Category 1 — Assistive Scale: SMB Applicable Frameworks: FTC Act Sec. 5, FDA mobile medical app guidance (if health claims), State consumer protection statutes, App store policies, COPPA (if under-13 users)
When the AI is the product, every output is a health claim.
The Governance Challenge
Fitness and wellness apps ship AI as the product itself — workout generators, meal planners, health coaching bots, and biometric interpreters. Every AI-generated recommendation is a consumer-facing health claim subject to FTC Section 5. If the app serves users under 13, COPPA applies. If the app makes health claims that cross into medical territory, FDA mobile medical app guidance triggers. Most wellness apps have no mechanism to govern what their AI recommends to users at scale.
Regulatory Application
FTC Act Section 5 applies to every AI-generated health and fitness claim. FDA mobile medical app guidance applies if outputs cross from wellness into clinical territory. COPPA applies if the app serves users under 13 — 2025 amendments expand the definition of personal information to include biometric identifiers. App store policies add a second governance layer. State consumer protection statutes apply to every jurisdiction where the app has users.
AI Deployment Environments
- Studio: Workout and nutrition content drafting | User FAQ generation | Onboarding copy
- Refinery: Health and fitness claims governance | Disclaimer enforcement | User safety content guardrails
Typical deployment path: Studio → Studio → Refinery
Evidence
- 48% internal adoption in wellness; 8% governance — a 34-point gap
- COPPA 2025 amendments expand personal information to include biometric identifiers (effective June 2025)
- FDA mobile medical app guidance applicability expanding