Executive Summary
This investigation exposes how multichannel affiliate marketing programs promote unregulated and potentially dangerous nutraceutical products in the EU. Our data collection builds on a pre-selected list of 390 products promoted across social media ads on Facebook and Google and targeting all EU countries. These products are advertised with unfounded medical claims, i.e., direct statements that they can cure chronic diseases such as diabetes or psoriasis or manage life-threatening conditions such as arrhythmia and high blood pressure. 20 percent of the products from this list have been flagged by official health authorities in the EU and other countries as illegal or dangerous to consumers.
Despite all this, their promotion on social media continues. We collected 350,549 Facebook ads and 2,073 Google ads launched between 2023 and 2026. The total EU reach of these Facebook ads is almost 878 million. The Google ads received between 5.9 million and 8.3 million impressions in the EU.
These advertising campaigns are characterized by numerous violations of the platforms’ own policies on both the content level (ads) and the behavioral level (advertisers).
On Facebook, ads and advertising pages impersonate medical doctors and celebrities and misuse the logos of pharmaceutical companies and other organizations to lend credibility to the promoted products. The content of these ads violates Meta’s advertising policies against treatments for incurable diseases, promotion of body dysmorphic images, pornography and adult nudity, trademark infringements, and ad cloaking. The advertising pages operate in coordination, and some originate from large-scale networks of automatically created burner accounts, previously known to Reset Tech and activated continuously since 2022 across multiple scam campaigns as well as the Russian influence operation Doppelganger. These pages repeatedly violate Meta’s policies on coordinated inauthentic behavior (CIB), yet the platform has allowed them to run ads for years.
On Google, networks of non-EU advertisers based in Brazil and Vietnam are allowed to run medical ads in the EU, with the platform leaving compliance with EU advertising standards to the advertisers’ discretion. Google’s Ads Transparency Center does not allow full insight into these campaigns due to limited search functionalities.
Neither Facebook nor Google systematically deplatforms problematic advertisers; instead, they focus mostly on removing individual ads. Unless addressed at a network level with stricter rules on health-related advertising, these campaigns will continue.
The platforms’ failure to mitigate these advertising campaigns constitutes a direct violation of Articles 34 and 35 of the EU’s Digital Services Act (DSA) regarding systemic risks to public health and the obligations of Very Large Online Platforms (VLOPs). Our investigation offers recommendations to platforms and regulators on how to address such high-risk advertising campaigns more effectively.
Click here to read the full report on the Reset Tech website.
