Key takeaways
- In July 2025, the FTC charged telehealth seller NextMed with using before-and-after photos of people who weren’t its customers to sell weight-loss drug programs; the agency finalized a $150,000 settlement in December 2025.
- Under the FTC’s Endorsement Guides, revised in 2023, a dramatic customer result is read as typical, and “results not typical” fine print doesn’t change that.
- In a blinded study of 153 face photos, light from a steep angle made the same people look heavier and less attractive to raters.
- Many conditions improve on their own: in studies of new low back pain, average pain scores fell by more than half within six weeks.
- Before you trust a transformation, check whether the photos match, how much time passed, what else changed and whether typical results are shown.
In July 2025, the Federal Trade Commission (FTC) took action against NextMed, a New York telemedicine company. It sold programs that connected members with providers who could prescribe weight-loss drugs such as Wegovy and Ozempic1.
According to the FTC, NextMed’s ads used before-and-after photos of people who were not its customers1. Its testimonials came from hired people, employees and family members who had never used the program or the drugs1. The company also claimed its members dropped an average of 53 pounds, or 23% of their weight, claims the FTC called unsupported1.
NextMed and its founders agreed to settle, and the FTC made the order final in December 202514. It requires $150,000 for consumer refunds and solid evidence for any claim about average or typical results114.
This is the twist. The drugs involved were real prescription medicines. The pictures, the FTC said, were not what they seemed.
That’s the core lesson of before-and-after marketing. A product can work or fail, and the photo can still mislead you. This guide explains the tricks, what federal rules require and how to read any transformation story with a clear eye.
A picture makes a promise the words may avoid
Before-and-after images do work that a written claim can’t. In a 2014 guide for media outlets, the FTC noted that weight-loss advertisers use eye-catching before-and-after pictures to put false claims across5. The same guide warned that advertisers often pick their best cases or simply invent endorsements5.
Pictures can also make health claims without saying them. The FTC’s 2022 health-products guidance describes an ad for a joint ointment4. The “before” shot shows an older woman using a walker. The “after” shows her dancing with her husband4.
The ad’s text talks only about joint health and mobility, though the product is called “Arthricure.” Even setting that name aside, the FTC says, the images plus the joint-health talk likely tell shoppers the ointment can dramatically ease arthritis. The seller would need scientific evidence for that claim4.
Stories work the same way. “I was exhausted for years, then I tried this” is a before-and-after in words. This library’s article on healing stories explains why such accounts feel so convincing.
The law: show typical results, or say what they are
The FTC’s Endorsement Guides, revised in July 2023, explain how the agency judges testimonials in ads2. The central idea is simple. When an ad shows a customer’s result on a main feature of a product, people will likely assume most buyers get something similar2. If the seller can’t back that up, the ad should clearly state the results people can generally expect2.
The guides walk through weight-loss examples2:
- The 50-pound photo. An ad shows before-and-after pictures of a woman who lost 50 pounds in six months. It should state the typical result, such as 15 pounds for women who use the product that long. A vague line like “Average weight loss is 1-2 pounds per week” isn’t good enough.
- The wrong body. A man truthfully says he went from 300 to 250 pounds on a shake. If the ad pairs his words with a photo of someone far thinner, the image misstates how well the product works.
- The hidden extras. A 110-pound loss in six months can be shown without implying it’s typical only if the ad clearly explains the unusual circumstances. In the FTC example, those included a raw-vegetable diet and six hours of exercise a day.
Fine print doesn’t fix a misleading photo. The FTC says phrases like “Results not typical” or “Individual results may vary” don’t change how people read a testimonial3.
The FTC’s health guidance gives a sharp example4. An ad shows a woman’s before-and-after photos and her 16-pound loss in eight weeks.
A well-run trial found the supplement produced only about 4 pounds more loss than a placebo, a dummy pill4. A tiny asterisk wasn’t enough. The FTC suggested printing the average result right next to her quote, in type people would notice4.
The guides also put it plainly: “Consumer endorsements themselves are not competent and reliable scientific evidence”2.
From “Big Fat Lie” to telehealth: cases on record
Weight-loss transformations have drawn federal enforcement for decades.
In November 2004, the FTC and partner agencies launched Operation Big Fat Lie, a crackdown on false weight-loss ads, including some in national magazines such as Woman’s Own6. The FTC also urged publishers and broadcasters to watch for seven “red flag” weight-loss claims6.
In early 2014, a newer sweep, reported as Operation Failed Resolution, targeted L’Occitane over a skin cream sold as a weight-loss aid and HCG Diet Direct over an unproven hormone product7. A partial settlement with LeanSpa dealt with fake news websites that promoted acai and colon-cleanse supplements7. Around the same time, the marketers of Sensa, sold with the promise “sprinkle, eat and lose weight,” agreed to pay $26.5 million7. The FTC released its “Gut Check” media guide in January 20145.
NextMed in 2025 shows how the playbook has moved to telehealth and prescription drugs1.
Seven ways a real photo can tell a false story
Outright fakes are only part of the problem. A real photo of a real person can still mislead you.
- Light. In a 2021 study in Aesthetic Plastic Surgery, researchers photographed 51 people with light coming from three angles: straight on, 30 degrees and 60 degrees8. Twenty-seven raters judged the 153 photos without knowing the setup. At 60 degrees, the same faces looked less attractive and heavier, and the lines from nose to mouth looked deeper8. The shifts were a fraction of a point on the raters’ scales, yet nothing about the faces had changed8.
- Pose and grooming. Standing taller, pulling in the stomach, tensing muscles, a tan, makeup, better clothes or a new haircut can change a picture in seconds. None of it needs a product.
- Camera setup. Distance, height and zoom all change proportions. The lighting study’s authors said light angle should be accounted for whenever face photos are documented or shown, and that their findings hold only if every other camera setting stays the same8.
- Editing and filters. Smoothing and slimming tools can reshape a face or body. Under FTC guidance, a misleading image is a misleading claim, even when the words beside it are true2.
- A different person. As the NextMed case shows, the “customer” may never have bought the product1.
- The best case only. One standout result says nothing about the average, as the FTC’s 16-pound example shows45.
- Something else changed. The FTC’s 110-pound example involved a strict diet and hours of daily exercise2. Real transformations usually involve many changes at once, and a photo can’t tell you which one mattered.
Time heals a lot, and photos can’t show it
The most common reason a “before” looks worse than an “after” may be the calendar.
Take new low back pain. A 2024 review in the Canadian Medical Association Journal pooled 47 groups of patients, about 9,200 people in all9. For people with acute back pain, meaning pain that started less than six weeks earlier, average pain fell from 56 to 26 on a 100-point scale within six weeks9.
An earlier 2012 review in the same journal, covering 33 groups and more than 11,000 people, found a similar early drop, from 52 to 2313. Any cream, pillow or supplement started in that window can look like a cure.
Skin conditions come and go too. The National Library of Medicine’s MedlinePlus says eczema in children often improves around age 5 or 6, though flare-ups are common, and many people outgrow it by early adulthood10. Acne usually fades after the teen years, and its treatments may take 6 to 8 weeks to work11. A two-month skin-care “transformation” fits right inside that natural window.
Then there’s regression to the mean. An unusually bad reading tends to be followed by a less extreme one, simply by chance. A 2003 BMJ paper by Vicki Morton and David Torgerson warned that trying a new treatment on the sickest patients will usually produce a sharp, gratifying improvement for this reason alone12. The same logic applies when you try a remedy on your worst day.
In one example they described, more than 80% of women whose bone density dropped during their first year of osteoporosis treatment gained bone the next year, with no change in treatment12. Had they switched to a new remedy after year one, the remedy would have looked like it worked.
None of this means nothing works. It means a single before-and-after can’t separate the product from time. Only a fair comparison group can do that.
A before-and-after checklist
Use this on any transformation photo, video or story. Each “no” or “can’t tell” is a reason for caution.
| Check | What a trustworthy example shows |
|---|---|
| Same conditions | Same light, angle, distance, pose, clothes, expression and time of day |
| Real customer | A real buyer, with consistent features and no sign of a stock or borrowed photo |
| Time between photos | Dated, and long enough apart that natural recovery can be ruled out |
| Other changes | Diet, exercise, medicines, procedures or other treatments are disclosed |
| Typical results | The average result appears near the photo, in readable type |
| Fair comparison | A controlled trial of this exact product, not just one of its ingredients |
| Paid connection | A clear disclosure if the person was paid, employed or given free product |
| Matching claim | The image doesn’t hint at a disease claim the seller never proves |
How to score it: If you count two or more “no” or “can’t tell” answers, treat the photo as an ad, not as evidence. Look for a controlled study before you spend money.
What a before-and-after can and can’t show
| Question | Evidence level | What it rests on |
|---|---|---|
| Do conditions like new back pain often improve on their own? | Pooled studies following thousands of patients over time9 | |
| Can photo conditions like lighting change how a result looks? | One blinded study of 153 photos, with modest effects8 | |
| Can one person’s before-and-after prove a product caused the change? | Natural recovery and regression to the mean can produce the same picture912 | |
| Are customer testimonials scientific proof? | The FTC says consumer endorsements aren’t reliable scientific evidence2 |
Honest progress photos are worth taking
Natural-health readers value effort, self-reliance and patience. Real transformations happen, and the people who make them deserve credit. The problem is using one person’s photo to sell a product to everyone else.
Your own photos can be honest evidence for you. Treat them like a small experiment:
- Take them in the same spot, with the same light, at the same time of day, in the same clothes.
- Add a number you can track, such as a waist measurement or a daily symptom score.
- Change one thing at a time when you can, and write down anything else that changed.
- Give it enough time, and remember that many problems ease on their own.
- If symptoms are severe, keep getting worse or last for months, see a clinician rather than waiting on a remedy.
When you share someone’s transformation in a group, ask permission first. Mention the other changes they made, and don’t promise others the same result.
How to report a misleading ad
- The FTC. Report deceptive health ads by phone at 1-877-FTC-HELP6 or online at ReportFraud.ftc.gov. If the website is down, use the phone line or your state’s office.
- Your state attorney general. Most have a consumer protection office that takes complaints about local and online sellers.
- The platform. Social media sites and marketplaces let you report an ad or a listing.
- If a product harmed you. Contact your clinician. For a possible poisoning, call Poison Control at 1-800-222-1222. In an emergency, call 911.
Questions readers ask
Are all before-and-after photos fake?
No. Many show real people with real results. The questions are whether that result is typical and whether the product, rather than time or other changes, caused it212.
Does “results not typical” make an ad honest?
No. The FTC says such phrases don’t change how people read a testimonial3. The seller must either prove the result is typical or clearly show what people generally achieve23.
What about photos from a clinic or cosmetic practice?
Ask whether the before and after shots were taken under the same lighting and settings, and ask for typical results, not just the best ones. The lighting study’s authors urged practitioners to account for light angle when they document and present photos8.
My friend’s transformation is real. Isn’t that proof?
It’s proof that your friend changed, which is worth celebrating. It can’t show which of the changes made the difference, or whether you would get the same result212.
The bottom line
A before-and-after photo is a story with the middle cut out. It can’t show the lighting choices, the months that passed, the other changes or the body’s own healing. Federal rules say a dramatic transformation must reflect typical results, and fine print doesn’t excuse it.
Enjoy real transformations, including your own. But before you buy, run the checklist. Ask whether the photos match, how much time passed, what else changed and what the average buyer gets. A fair comparison, not a single face, tells you whether something works.
Related reading
About this article
This article was researched using Federal Trade Commission rules, guidance and enforcement records, peer-reviewed studies and National Library of Medicine health pages, all listed below. It was reviewed in October 2026. It is general education, not medical, legal or financial advice.
Sources
- Federal Trade Commission. “FTC Takes Action Against Telemedicine Firm NextMed Over Charges It Used Misleading Prices, Fake Reviews, and Deceptive Weight Loss Claims to Sell GLP-1 Weight-Loss Programs.” Press release, July 14, 2025. ftc.gov
- Federal Trade Commission. “Guides Concerning the Use of Endorsements and Testimonials in Advertising,” 16 CFR Part 255 (revised July 26, 2023, 88 FR 48102). Electronic Code of Federal Regulations, accessed October 2026. ecfr.gov
- Federal Trade Commission. “FTC’s Endorsement Guides: What People Are Asking.” Updated July 2025. ftc.gov
- Federal Trade Commission. “Health Products Compliance Guidance.” December 2022. ftc.gov
- Federal Trade Commission. “Gut Check: A Reference Guide for Media on Spotting False Weight Loss Claims.” January 2014. ftc.gov
- Federal Trade Commission. “FTC Stops Bogus Ads for ‘Bio Trim’ and Other Weight-loss Products.” Press release, November 7, 2005. ftc.gov
- Bangor Daily News. “Weight-Loss Scams Prey on the Unsuspecting.” January 12, 2014. bangordailynews.com
- Hernandez CA, Espinal JM, Uribe Zapata D, et al. “The Influence of Different Light Angles During Standardized Patient Photographic Assessment on the Aesthetic Perception of the Face.” Aesthetic Plastic Surgery, 2021. link.springer.com
- Wallwork S, Braithwaite F, O’Keeffe M, et al. “The Clinical Course of Acute, Subacute and Persistent Low Back Pain: A Systematic Review and Meta-Analysis.” CMAJ, 2024 (record at University of Notre Dame Australia). researchonline.nd.edu.au
- MedlinePlus, National Library of Medicine. “Atopic Dermatitis.” Reviewed October 13, 2024. medlineplus.gov
- MedlinePlus, National Library of Medicine. “Acne.” Reviewed August 2, 2025. medlineplus.gov
- Morton V, Torgerson DJ. “Effect of Regression to the Mean on Decision Making in Health Care.” BMJ, 2003 (White Rose Research Online). pubmed.ncbi.nlm.nih.gov
- Menezes Costa LC, Maher CG, Hancock MJ, et al. “The Prognosis of Acute and Persistent Low-Back Pain: A Meta-Analysis.” CMAJ, 2012 (record at Macquarie University). researchers.mq.edu.au
- Federal Trade Commission. “FTC Approves Final Order against Telehealth Provider NextMed Over Charges It Used Deceptive Advertising Claims to Sell GLP-1 Weight-Loss Programs.” Press release, December 3, 2025. ftc.gov