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Claims Substantiation

Last Updated December 2025

Use of this Website constitutes acceptance of Viori’s Terms and Conditions of Use, Disclaimers, and this Claims Substantiation page. By continuing to browse or shop on this site, you acknowledge and agree that claims made by Viori are subject to the limitations, scope, and explanations set forth herein.

This Claims Substantiation page is provided to explain the basis, scope, and limitations of claims made across Viori’s website, packaging, marketing materials, and third-party platforms.

1. Claims Framework & Regulatory Basis

Viori designs, markets, and substantiates claims in accordance with applicable U.S. laws and guidance, including:

  • Federal Trade Commission (FTC) advertising substantiation standards

  • U.S. Food & Drug Administration (FDA) cosmetic and dietary supplement regulations

  • Dietary Supplement Health and Education Act (DSHEA) requirements

Governing Principles

  • All claims are intended to be truthful, not misleading, and supported by a reasonable basis at the time made

  • Claims are cosmetic-appearance or structure/function in nature unless explicitly stated otherwise

  • Viori does not make drug claims, disease claims, or claims of medical treatment

Primary Regulatory References:

  • FTC Advertising Substantiation Policy

    https://www.ftc.gov/legal-library/browse/ftc-policy-statement-regarding-advertising-substantiation

  • FTC Substantiation Training Materials (PDF)

    https://www.ftc.gov/sites/default/files/attachments/training-materials/substantiation.pdf

  • FDA – Is It a Cosmetic, a Drug, or Both?

    https://www.fda.gov/cosmetics/cosmetics-laws-regulations/it-cosmetic-drug-or-both-or-it-soap

  • FDA – Cosmetic Labeling & Claims

    https://www.fda.gov/cosmetics/cosmetics-labeling/cosmetics-labeling-claims

  • DSHEA Disclaimer Requirements (21 CFR §101.93)

    https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-F/section-101.93

2. Scope of Claims (Important)

Claims made by Viori:

  • Are product-specific and context-specific

  • Do not apply universally to all products, packaging formats, or historical offerings

  • May vary by formula, ingredient composition, usage pattern, and individual experience

  • Should not be interpreted as guarantees of results

Individual results may vary.

3. System-Level Claims — The Full-Hair Ritual™

What Is Claimed

Viori’s Full-Hair Ritual™ is described as:

  • A coordinated system of hair-care products, dietary supplements, and professional spa rituals

  • Designed to support the appearance of fuller-looking, longer-looking, and healthier-looking hair through consistent use*

Explicit Boundaries

Viori does not claim:

  • Hair regrowth

  • Follicle stimulation

  • Treatment or prevention of hair loss

  • Medical or pharmaceutical outcomes

All system-level claims are cosmetic-appearance or structure/function in nature.

4. Cosmetic Hair Appearance Claims

Across Viori’s topical products, spa rituals, and supporting materials, the following appearance-based claims may be used:

  • Thicker-looking hair*

  • Fuller-looking hair*

  • Longer-looking ends due to reduced breakage*†

  • Less visible hair fall-out due to reduced breakage*†

  • Improved hair fiber tensile strength*‡

  • Soft, smooth, healthy-looking hair*

* Not evaluated by the FDA

† Due to reduced breakage

‡ Due to improved tensile strength

Substantiation Basis

These claims are supported by:

  • Established cosmetic science demonstrating that reduced breakage, conditioning, and fiber reinforcement improve perceived length, density, and hair appearance
  • Ingredient-function rationale consistent with cosmetic use
  • Internal product testing, consumer perception studies, and instrumental measurements (where applicable)

Supporting Scientific Literature:

  • Hair breakage during combing and conditioning effects

    https://pubmed.ncbi.nlm.nih.gov/17728947/

  • Mechanical hair damage and breakage mechanisms

    https://pubmed.ncbi.nlm.nih.gov/18305876/

5. Ingredient Story & Safety Substantiation

Longsheng Rice Protein™

Viori’s use of Longsheng Rice Protein™ is:

  • Inspired by traditional Red Yao hair-care practices

  • Valued for supporting smoothness, shine, strength, and overall hair appearance*

  • Used as a unifying cosmetic and formulation concept across select products

Longsheng Rice Protein™ may include one or more of the following components, depending on product formulation:

  • Longsheng Rice Flour

  • Longsheng Rice Water

  • Longsheng Rice Water + Longsheng Rice Flour

  • Longsheng Rice Flour combined with hydrolyzed rice protein

  • Longsheng Rice Water combined with hydrolyzed rice protein

Both Longsheng Rice Flour and Longsheng Rice Water naturally contain rice-derived proteins and starches commonly used in cosmetic formulations.

Ingredient Safety References

  • Cosmetic Ingredient Review (CIR) — Rice-derived ingredients

    https://pubmed.ncbi.nlm.nih.gov/17090480/

  • CIR — Hydrolyzed Rice Protein

    https://www.cir-safety.org/ingredient/hydrolyzed-rice-protein

  • CIR — Plant-derived proteins safety assessment (PDF)

    https://www.cir-safety.org/sites/default/files/Plant%20Proteins.pdf

Viori does not claim genetic, ethnic, or biological superiority associated with any ingredient.

6. Dietary Supplement Claims (Structure / Function Only)

Permitted Claims

For dietary supplements, Viori may use claims such as:

  • Supports the appearance of healthy-looking hair*

  • Supports hair fiber structure and cosmetic strength*

  • Supports overall beauty appearance consistency*

These claims are made in compliance with DSHEA and include the required disclaimer:

These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.

Supporting References

  • NIH Office of Dietary Supplements — Biotin Consumer Fact Sheet

    https://ods.od.nih.gov/factsheets/Biotin-Consumer/

  • DSHEA Disclaimer Requirements

    https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-F/section-101.93

Viori does not claim to treat nutrient deficiencies, stimulate hair growth, or alter biological hair growth cycles.

7. Fair Trade Claim Substantiation

Viori substantiates its use of the term “Fair Trade” through documented, ongoing direct-trade relationships with producer communities, most notably the Red Yao communities of Longsheng, China.

These relationships emphasize ethical sourcing practices rather than reliance on third-party certification.

Key Supporting Elements

  • Direct sourcing relationships with Red Yao community partners

  • Premium pricing above local market rates for Longsheng rice and related materials

  • Long-term partnership commitments rather than one-time or spot purchases

  • Community-directed reinvestment, including financial contributions and project support

  • Ongoing engagement, transparency, documentation, and public reporting

Important Clarification

Viori’s use of “Fair Trade” does not indicate certification by a third-party fair-trade organization unless explicitly stated. Rather, it reflects Viori’s direct-trade sourcing model, which the company believes aligns with widely recognized fair-trade principles, including fairness, transparency, sustainability, and community well-being.

Certified by Fair Trade USA since August 2021 — present.

8. Environmental & Sustainability Claims

Environmental claims (such as “plastic-free,” “plastic-reduced,” or sustainability-related statements) are intended to be understood by a reasonable consumer and are limited by:

  • Product format

  • Packaging component

  • Distribution and fulfillment channel

Regulatory Reference

  • FTC Green Guides — Environmental Marketing Claims

    https://www.ftc.gov/system/files/documents/public_events/975753/ftc_-_environmental_claims_summary_of_the_green_guides.pdf

Additional explanations and limitations are provided on Viori’s Disclaimers page.

9. Definitions, Certifications & Marketing Terminology Clarifications

The following terms may appear across Viori’s website, packaging, marketing materials, and third-party platforms. These terms are defined below to clarify their intended meaning, scope, and limitations.

Unless explicitly stated otherwise, these terms are descriptive, non-regulatory marketing language and should not be interpreted as guarantees, regulatory approvals, or universal product claims.

 

All Natural

“All natural” refers to formulas composed primarily of plant-based, naturally derived ingredients and excludes synthetic sulfates, parabens, phthalates, and silicones. Certain naturally derived ingredients may be processed for safety, stability, or cosmetic performance.

 

Sustainable

“Sustainable” reflects Viori’s efforts to reduce environmental impact through responsible sourcing, ethical partnerships with the Red Yao communities, reduced plastic formats, and long-term environmental initiatives. Sustainability is an evolving practice and does not imply zero environmental impact.

 

Eco-Friendly

“Eco-friendly” describes product formats, packaging, or practices designed to reduce environmental impact relative to conventional liquid haircare and body care products. No product or process is entirely impact-free.

 

Zero Waste

“Zero waste” refers to Viori’s goal of minimizing waste through solid bar formats, biodegradable product compositions, and plastic-free primary packaging. While these formats significantly reduce waste compared to conventional alternatives, some waste may still occur across the supply chain.

 

Vegan

“Vegan” means products are formulated without animal-derived ingredients and are not tested on animals.

Certified by Vegan International since January 2022 — present.

 

pH Balanced

“pH balanced” indicates products are formulated within a pH range generally considered suitable for hair and scalp health. Body care products are formulated within a pH range generally considered suitable for skin. Individual results may vary based on hair type, skin type, condition, and usage.

 

Made in USA

“Made in USA” indicates products are manufactured and assembled in the United States using both domestic and globally sourced ingredients.

 

Professional Grade

“Professional grade” refers to formulation quality and performance standards commonly used by salon professionals. Products are formulated without harsh sulfates and are generally suitable for color-treated hair. This term reflects formulation design and ingredient performance and does not indicate a regulatory classification or licensing status.

 

Color Safe

“Color safe” means products are formulated without harsh sulfates and are generally suitable for color-treated hair. Results may vary based on hair type, color treatment, and individual routine.

 

Responsible Palm (RSPO)

Viori uses palm-derived ingredients sourced in alignment with RSPO (Roundtable on Sustainable Palm Oil) standards.
 RSPO participation active since August 7, 2021 — present.

 

Leaping Bunny Certified

“Leaping Bunny” indicates participation in cruelty-free standards prohibiting animal testing at any stage of product development.
Active since April 9, 2021 — present.

 

ISO Certified

“ISO certification” refers to manufacturing partners that operated in alignment with applicable International Organization for Standardization guidelines during a defined period.

ISO alignment period: May 2023 – May 2025

 

EU Compliance Standards

“EU compliance standards” indicate that certain product formulations were developed to align with applicable European Union cosmetic regulations, including restricted ingredient lists and safety requirements.

EU compliance alignment period: May 2023 – May 2025

 

Carbon Neutral

“Carbon neutral” refers to a defined historical period during which operational emissions were measured and offset through third-party programs.

Carbon neutrality applied from June 2022 – May 2023

 

GMP Compliance

“GMP compliant” indicates that manufacturing partners currently operate in accordance with Good Manufacturing Practice standards applicable to cosmetic production.

Status: Currently compliant.

 

Clean Fragrance

“Clean fragrance” means our scents are made with plant-based or naturally derived ingredients and are screened for safety and quality. They are free from phthalates and harsh chemicals, meet global fragrance safety standards (including IFRA and EU regulations), and are designed to be gentle for everyday use. Our fragrance ingredients are rated 0 on the Think Dirty® app.

10. Final Notes

  • Claims evolve as formulations, sourcing, and packaging evolve

  • Viori reviews claims regularly to ensure continued compliance

  • This page is incorporated by reference into Viori’s Terms of Service

For additional disclosures, limitations, and clarifications, please review: