Executive Summary

Sarpes Beverages supports its core efficacy message and representations that Dream Water 0 Calorie Sleep and Relaxation Drink is the "first water that helps you relax and fall asleep," the Electronic Retailing Self-Regulation Program says in a review of the company's online advertising. However, ERSP advised the direct response marketer to discontinue express performance claims regarding specific elements of product performance described by consumers in ads. For example, the testimonial, "In about 20 minutes I started to get pretty tired. I went to bed and fell asleep in no time," should be discontinued. FTC guidelines for testimonials state that claims must be substantiated by reliable scientific evidence, the division of the National Advertising Review Council says. Sarpes, which markets its Dream Water as a flavored water containing three natural relaxation ingredients - y-aminobutyric acid, melatonin and 5-hydroxytryptophan - said it will include ERSP's recommendations in future ads