Along with many other people in the marketing world, I was shocked to see that the FDA wrote a warning letter to General Mills, charging that it was making drug-like claims on its Cheerios brand. For two years, the brand has spent tens of millions of dollars on TV, print, packaging, and the Web to advertise the claim that “Cheerios lower your cholesterol 4% in 6 weeks.” The Cheerios brand has been around for decades and many adults and children have been raised on the popular cereal. It has become what its agency, Saatchi & Saatchi, calls a “Lovemark.” But its words seem to have gone too far, and I believe the brand could have done more action to lower cholesterol and improve lives.

In analyzing this case, I first went to my friend and coworker, Jonathan Richman, a former pharma marketer who is now running Business Development at Bridge Worldwide. Richman recently created a new blog, Dose of Digital, where he has attracted a huge following to his posts on pharma and health care digital marketing. He provided some very compelling arguments that the FDA is doing the right thing by questioning the Cheerios claims:

This protects the public because it ensures that there is consistent enforcement of very clear rules for making medical claims in this country. If a pharma company didn’t bother to do a randomized, controlled trial and claimed that their new drug improved cholesterol, there would be an outrage in the public and the FDA would act almost instantly. Why is it different when a cereal company does it? If you let one company get away with it, you embolden others and lose all of the precedent that the FDA has carefully created over the years.”

Richman’s recommendation is for Cheerios to either drop the claim or to invest in the randomized, placebo-controlled trials with tens of thousands of people like pharma companies do. After 2 to 3 years including study time and considerable expense, the brand might have something that it can take to its advertising agency for TV and print ad production.

Richman and other experts predict that Cheerios will press the issue a bit but will eventually have to withdraw its claim and pull the heart off the box, as it should. But it didn’t have to be this way. I believe Cheerios missed an opportunity to make more of a commitment to its consumers by going beyond a claim and developing a program that can make a real, proven difference in people’s lives.

Let me share the example of one of our clients, the Glucerna brand at Abbott Nutrition. Glucerna is a brand of shakes, cereals, and bars for people with diabetes. These products offer a meal replacement or supplement for a group that has to watch its food carefully. Glucerna has a slow-absorbing carbohydrate, among other benefits, which helps avoid blood sugar spikes.

More than seven years ago, the Glucerna brand saw an opportunity to make a meaningful difference in the lives of people with diabetes. In 2002, it created Diabetes Control for Life, a customizable program that helps people change their lifestyle and eat better, exercise more, and measure their blood sugar levels more often. The program does not require people to eat or drink Glucerna, but it suggests meals and snacks where its products are a good choice. Other foods can easily be substituted in the plan.

The company funded a 24-week clinical study to prove the benefits of the program, which were significant:

• Average of 7.5% weight loss
• 61% reported lower A1C levels.
• 73% felt more confident in managing their disease.

Five years ago, we moved the Diabetes Control for Life program to the Web, which includes a very in-depth interactive meal and exercise tracker. We have continually added many other features to help people with diabetes, including a diabetes glossary, discussion board, and ability to IM a dietitian. Traffic continues to increase and other retailers and brands have partnered with us to expand the program.

Cheerios could have done something along these lines. A vast majority of its spending has been on traditional marketing of its claim through mass media. At Cheerios.com there are a few resources for overall cholesterol improvement, essentially a handful of articles and a printable PDF tracking sheet.

With a more comprehensive plan that offers more resources and doesn’t require Cheerios consumption, plus proven test results over many weeks, the brand might have been able to make more than a supposed 4% improvement in cholesterol levels, and it might not have the FDA breathing down its back today.

But it’s not too late! If the brand truly believes that it can make a difference and is truly committed to improving consumers’ health, it can pull back for now, and build out a bigger and better program. So, General Mills, call the lawyers back, pull the claim off the market, and drop us a line if you’re ready to embrace true marketing with meaning.