Bon Charge - Marketing Compliance Reference

Compiled: 2026-04-25 Author: Tethrd (synthesised from Bon Charge compliance materials) Escalation contact: Dr Ana Martins — ana@boncharge.com

Source documents:

• BC Collections Permissible Claims V1.0 (Feb 2026)
• BC Marketing Compliance Cheat Sheet V1.1 (Living Document, Feb 2026)
• Compliance Language Training — Dr Ana Martins (Sep 2025)
• UGC Compliance Blueprint (Mar 2026)
• Compliance Training Meeting Transcript (Apr 2026)
• 15 product user manuals (Nov 2025)

How to use this document

Before writing any ad copy, brief, script, caption, or CS response:

1. Check Section 2 — global forbidden language
2. Check Section 4 — per-product permitted/forbidden claims and safety requirements
3. Check Section 5 — market-specific rules (US vs global)
4. Check Section 6 — visual and UGC compliance
5. When in doubt: escalate to ana@boncharge.com — she provides compliant replacement language, not just flags

Hierarchy of truth (in order):

1. User manual ("the Bible" — always current, always safe)
2. BC Collections Permissible Claims V1.0 + UGC Blueprint Mar 2026 + Cheat Sheet V1.1
3. boncharge.com (some pages under audit — may contain non-compliant language; do not rely on)
4. This document (synthesises all of the above)

Section 1 - Regulatory baseline

1.1 Standard applied

All Bon Charge marketing defaults to the Australian TGA (Therapeutic Goods Administration) Advertising Code — the strictest market Bon Charge operates in. TGA compliance = compliant everywhere (FDA, MHRA, EU).

1.2 Brand positioning anchor

"BON CHARGE is all about wellness, recovery, and beauty — not health." Even where products are registered as medical devices, they must NOT be promoted for therapeutic purposes.

1.3 Bon Charge's liability

Bon Charge is the sponsor (not the manufacturer). Any non-compliant claim made by any third party — influencer, UGC creator, agency, SAB member — that Bon Charge paid for or published makes Bon Charge liable.

1.4 The 8 TGA principles (mandatory for all advertising)

1.5 The 10 absolute prohibitions (no exceptions, ever)

Section 2 - Global forbidden language (all products)

2.1 Therapeutic language

2.2 Medical conditions (never name as a product benefit)

2.3 Biological processes (forbidden to claim directly)

2.4 Skin claims (forbidden)

2.5 Outcome and efficacy claims (forbidden)

2.6 Intensity and certainty words (forbidden)

2.7 EMF and radiation language

• Never use "radiation" as a standalone word — it is a fear trigger
• Never say "protect yourself from harmful radiation"
• Never say "artificial light is electromagnetic radiation" without full context (misleading by omission)
• Use "EMF" or "EMF emissions" — not "EMF radiation" as a scare phrase
• Fear-based framing ("protect yourself from blue light harm") violates the fear prohibition

Section 3 - Global permitted language and reframes

3.1 Safe claim starters (pre-approved)

• "Designed to help..."
• "May support..."
• "Part of my wind-down routine..."
• "Helps create an environment for..."
• "I like how it feels... / For me, it feels..."
• "Supports [outcome]..."
• "Science-backed..."
• "Evidence-backed..."
• "Scientifically demonstrated..."
• "As part of your [ritual / routine / session]..."

3.2 Permitted reference to science

• Permitted: "evidence-backed", "backed by science", "scientifically demonstrated", "science-based", "scientifically researched", "demonstrated"
• Permitted: educational carousel citing a peer-reviewed study (claim attributed to the study, not to the product)
• Forbidden: "clinically proven", "clinically tested", "clinically verified"
• Distinction: scientific data = university/hospital research. Clinical data = commercially sponsored trials. Bon Charge has not run commercial trials. "Clinical" language is categorically off-limits.

3.3 Specific claim nuances

• "Improves" — high-risk certainty claim. Replace with "may support"
• "Safe" — never use. Not even "safe for the whole family". Saying it is safe encourages skipping the user manual.
• "Red light, a drug-free way to relieve sore muscles" — forbidden. Implies pharmaceutical alternatives are less effective (denigration)
• Percentage claims — never use ("20% more effective", "results in 7 days"). No specific timelines or guaranteed percentages.
• Image context — a borderline claim becomes non-compliant if the image shows a condition (e.g., "calms redness" is conditionally permitted in copy, but non-compliant if the image shows acne or rosacea)

3.4 Required disclaimer (mandatory on all UGC and all content where health claims are made)

"Products are intended for general wellness. Not intended to diagnose, treat, cure, or prevent any disease or medical condition. Always read the instructions and follow the directions for use. Individual results may vary."

Section 4 - Per-product compliance reference

4.1 Red Light Face Mask

Price: $349 | Wavelengths: Red 630nm + NIR 850nm

Intended use (exact manual wording): "This device is a wellness device aimed at improving the appearance of skin and general wellness benefits for the user."

Permitted claims:

• Supports skin appearance / radiant-looking complexion
• Softer-looking fine lines over time
• Supports skin elasticity, texture, firmness
• Supports glow and even-looking tone
• Calms redness (only if visuals show no acne or rosacea)
• Clearer, smoother-looking skin over time
• Part of a calming self-care routine / skincare ritual
• Science-backed beauty technology

Forbidden claims:

• Treats / heals acne, rosacea, eczema, or any skin condition
• Collagen production (use educational carousel with study citation instead)
• Clinically proven / clinically tested
• Repairs skin / skin renewal as a cellular claim
• Before/after photos showing acne resolution — forbidden even if genuine

Contraindications (must not use without doctor approval):

• Pregnant
• Taking photosensitising drugs (Tetracycline, Digoxin, Retin A, steroids)
• Suspicious or cancerous lesions
• Recent steroid injection or topical steroid use
• Serious medically diagnosed condition
• Heart condition or pacemaker

Safety requirements:

• Eye cups included in box — must be used during sessions
• Use on clean, dry skin only
• Do not use on wet skin, open wounds, or with salves/balms/ointments
• Photosensitivity test required before first use (forearm test, 2 min, 1 inch from skin)
• Do not exceed 30 minutes per session
• First-time ramp: start at 2-3 min, build to 10 min over 2-3 weeks
• Minimum 3 sessions per week; daily ideal
• For indoor use only

CS routing: Pregnancy, pacemaker, cancer, or photosensitivity questions → always advise consult healthcare professional before use

4.2 Red Light Neck and Chest Mask

Price: $349 | Wavelengths: Red 630nm + NIR 850nm

Intended use: Same as Face Mask — "wellness device aimed at improving the appearance of skin and general wellness benefits."

Permitted claims: Same as Face Mask — skin appearance, texture, tone, elasticity. Neck and décolletage positioning.

Forbidden claims: Same as Face Mask.

Contraindications: Identical to Face Mask (pregnant, photosensitisers, cancerous lesions, steroids, serious medical condition, heart/pacemaker).

Safety requirements:

• No eye cups (product does not cover the face) — but warn against staring directly at LEDs
• Same session limits as Face Mask: 10 min minimum, 30 min maximum
• Same ramp protocol and frequency
• Do not use on wet skin, open wounds, with salves/balms/ointments

4.3 Red Light Face Wand

Price: $149 | Tech: Red LEDs + sonic vibration + warm induction heating

Intended use (exact manual wording): "This product is a general use beauty product aimed at reducing the appearance of fine line and wrinkles, help depuff the skin and reducing the signs of aging."

Permitted claims:

• Reduces the appearance of fine lines and wrinkles
• Helps de-puff the skin
• Reduces the signs of ageing
• Supports a refreshed complexion
• Beauty entry-point / daily skincare ritual
• Apply directly to skin — hands-free ritual
• Use on clean, dry skin; follow with serums and moisturiser
• Always follow with SPF if using during the day

Forbidden claims:

• No goggles required (confirmed in manual: "Protective goggles are not required when using the Red Light Face Wand")
• No distance requirements — applied directly to skin
• Treats skin conditions; any collagen claim; clinically tested

Contraindications: Same as Face Mask (pregnant, photosensitisers, cancerous lesions, steroids, serious medical condition). Manual specifies: Tetracycline, Digoxin, and Retin A by name.

Safety requirements:

• Applied directly to skin — no distance requirement
• No goggles required
• Use on clean, dry skin only; do not use on wet skin, open wounds, with salves/balms
• 5-10 min sessions; first-time ramp: 2-3 min building to 10 min over 2-3 weeks
• Maximum 20 minutes per session
• Daily use; minimum 4 times per week
• Photosensitivity test before first long use (forearm test, 2 min)
• Follow with SPF if used during the day

CS routing: Same contraindication routing as Face Mask. Highlight: wand is beauty-positioned — keep all claims in appearance/de-puffing territory.

4.4 Mini Red Light Therapy Device

Price: $299 | Wavelengths: Red 660nm + NIR 850nm

Intended use: "Wellness device aimed at improving the appearance of skin and general wellness benefits for the user."

Permitted claims:

• Post-activity muscle comfort
• Recovery ritual after training or long days
• Skin appearance support (red light component)
• Relaxation / restful environment
• Science-backed recovery technology
• Targeted use on specific areas

Forbidden claims: Treats injuries, heals muscles/joints, clinically proven, clinically tested, muscle repair, circulation.

Contraindications:

• Pregnant
• Photosensitising drugs (Tetracycline, Digoxin, Retin A)
• Suspicious or cancerous lesions
• Recent steroid injection or topical steroids
• Do not use on infants

Safety requirements:

• Protective goggles included in box and recommended — "Protective goggles are recommended to be worn when using red light." (recommended, not mandatory per manual wording)
• Do not stare directly into LEDs
• Distance: 1-3 inches to 1 foot from body ("Placing the device directly on bare skin may result in burns or injury")
• Maximum session: 20 minutes
• Recommended session: 10 minutes
• First-time ramp: 2-3 min building to 10 min over 2-3 weeks
• Minimum 4 sessions per week; daily ideal
• Photosensitivity test before first long use (forearm, 4 min, 3 inches from skin)
• Indoor use only; do not use on wet/damp skin, open wounds, with salves/balms

Creative compliance note: Must show goggles in UGC/visual content even though manual says "recommended" — the spirit of the safety requirement is that users wear them.

4.5 Demi Red Light Therapy Device

Price: $699 | Wavelengths: Red 660nm + NIR 850nm

Intended use: Same as Mini — wellness device for skin appearance and general wellness.

Permitted claims: Same as Mini — post-activity comfort, recovery ritual, skin appearance, relaxation, science-backed.

Forbidden claims: Same as Mini.

Contraindications: Identical to Mini (pregnant, photosensitisers, cancerous lesions, steroids, no infants).

Safety requirements:

• Protective goggles included and recommended — "Protective goggles have been supplied for your protection. We recommend wearing these when using your red light Device."
• Distance: 3 inches to 1 foot from body (same minimum as Mini)
• Maximum session: 20 minutes per cautions section (timer allows 30 min — use 20 min limit in marketing)
• Recommended session: 10 minutes
• Same ramp protocol and frequency as Mini
• Up to 3 sessions per day permitted by manual for "major injury, long term aches and pains or severe skin conditions" — do NOT use this in marketing copy (encourages excessive use of medical framing)
• Photosensitivity test required (forearm, 4 min, 3 inches from skin)

4.6 Max Red Light Therapy Device

Price: $999 | Wavelengths: Red 660nm + NIR 850nm

Intended use (exact manual wording): "This device is a wellness device aimed at improving the appearance of skin and general wellness benefits for the user."

Permitted claims: Same as Demi — post-activity comfort, recovery ritual, skin appearance, science-backed.

Forbidden claims: Same as Demi — no treating injuries, no muscle/joint repair, no circulation, no clinically tested.

Contraindications:

• Pregnant
• Photosensitising drugs (Tetracycline, Digoxin, Retin A)
• Suspicious or cancerous lesions
• Recent steroid injection or topical steroids
• Do not use on infants

Safety requirements:

• Goggles included in box and recommended — "Protective goggles have been supplied for your protection. We recommend wearing these when using your red light Device." (manual uses "if required" / "we recommend" — not mandatory language, but show goggles in all visual content)
• Distance: 3 inches to 1 foot from body (minimum 3 inches — "Placing the device directly on bare skin may result in burns or injury")
• Maximum session: 20 minutes (Cautions hard cap — timer allows 30 min, use 20 min limit in marketing)
• Recommended session: 10 minutes
• First-time ramp: 2-3 min building to 10 min over 2-3 weeks
• Minimum 4 sessions per week; daily ideal
• Photosensitivity test required (forearm, 4 min, 3 inches from skin)
• Indoor use only; do not use on wet/damp skin, open wounds, with salves/balms

Note on "up to 3 times per day" language in manual: The manual states this for injury/severe skin conditions — do NOT use in marketing copy (encourages medical framing and excessive use).

4.7 Super Max Red Light Therapy Device

Price: $1,599 | Wavelengths: Red 660nm + NIR 850nm

Intended use (exact manual wording): "This device is a wellness device aimed at improving the appearance of skin and general wellness benefits for the user."

Permitted claims: Same as Max — post-activity comfort, recovery ritual, skin appearance, whole-body panel. Fulham FC athletic recovery angle is strong permitted territory.

Forbidden claims: Same as Max.

Contraindications: Identical to Max (pregnant, photosensitisers, cancerous lesions, steroids, no infants).

Safety requirements:

• Goggles included in box and recommended — same language as Max: "Protective goggles have been supplied for your protection. We recommend wearing these." (show in all visuals)
• Distance: 3 inches to 1 foot from body minimum
• Maximum session: 20 minutes (hard cap per Cautions — timer allows 30 min)
• Recommended session: 10 minutes
• Same ramp protocol and frequency as Max
• Same photosensitivity test required (forearm, 4 min, 3 inches from skin)
• Indoor use only; same wet/wound/salves restrictions

4.8 Red Light Therapy Blanket

Price: $1,999 | Wavelengths: Red 660nm + NIR 850nm

Intended use (exact manual wording): "This product is a general use wellness product and is not intended to prevent, cure or treat any medical condition."

Permitted claims:

• Post-activity muscle comfort
• Recovery ritual after training or long days
• Full-body red light session at home
• Supports skin appearance (red light component)
• Relaxation / restful environment
• Science-backed recovery technology

Forbidden claims: Same as red light panel range — no treating injuries, no muscle repair, no circulation, no clinically tested.

Contraindications (this product has the most detailed list in the range):

• Open or bleeding wounds — hard stop
• Pregnant or planning to become pregnant or breastfeeding — hard stop ("Do not use this product if you are, suspect you may be, or are planning to become pregnant")
• Cancer or suspected cancerous lesions — hard stop ("Do not use over malignant or benign tumors")
• Epilepsy or seizures triggered by flashing lights — consult physician first (device pulses at 10Hz)
• Under care of physician for pre-existing condition — consult physician
• Steroid medication or injections — consult physician
• Recent surgery, LASIK/PRK eye surgery, or skin filler injections — consult physician
• Breast implants — consult physician
• Tattoo in the treatment area — consult physician
• Light/sunlight sensitivity conditions (Lupus, eczema, light-induced migraines, albinism, rosacea) — consult physician
• Photosensitising medications (antibiotics, chemotherapy drugs, allergy medications, pain medications, diuretics) — consult physician
• St John's Wart, citrus essential oils, antibacterial soap, coal tar products — consult physician

Additional: device is only suitable for adults 18 years and older. Not suitable for children or pregnant women.

Safety requirements:

• Goggles required — provided in box and must be worn
• Photosensitivity test before first long session (forearm, 2 min, 1 inch from skin)
• Sessions: 5-20 min recommended; hard limit 30 minutes
• Minimum 3 sessions per week; daily use ideal
• Do not operate while sleeping
• 10Hz pulsed light — flag for users susceptible to photosensitive epilepsy

CS routing: Pregnancy, cancer, surgery, implants, epilepsy questions → hard stop, advise consult physician before use.

4.9 Red Light Cap

Price: $449 | Wavelength: Red 650nm | LEDs: 125 red LEDs

Version split:

• Non-TH (AU, UK, EU, ROW): Beauty/hair wellness positioning
• TH (US market): Therapeutic positioning (references clinical hair thinning pattern scales)

Intended use (both versions — exact wording): "Designed to deliver red LED light to capillary hair follicles to stimulate hair growth and promote thicker, healthier-looking hair."

Permitted claims — both versions:

• Stimulate hair growth
• Promote thicker, healthier-looking hair
• Encourages natural hair follicle activity
• Help stimulate capillary hair growth
• Support fuller hair
• Non-invasive, hands-free, 10-minute daily session at home

Permitted — TH version only (US):

• Referencing Hamilton-Norwood Scale (male pattern thinning, IIa-V)
• Referencing Ludwig-Savin Scale (female pattern thinning, I-1 to I-4, II-1, II-2, frontal)

Forbidden claims (all markets):

• Reverses baldness / reverses hair loss
• Treats androgenetic alopecia (non-TH markets)
• Treats or cures any diagnosed hair condition
• Clinically proven / clinically tested
• Guaranteed regrowth

Contraindications (both versions — identical):

• 18 years old or younger — hard stop
• Pregnant, planning pregnancy, or breastfeeding — hard stop
• Cancer or undergoing cancer treatment — hard stop
• Light-sensitive conditions, seizures, epilepsy, light-induced headaches — hard stop
• Allergic to non-latex rubber, plastics, fabrics, or metals — hard stop
• Photosensitising medications (e.g., tetracyclines) — hard stop
• Phlebitis, thrombophlebitis, varicose veins — hard stop
• Recent surgery unless cleared by healthcare professional — hard stop
• Fever, acute inflammation, severe circulatory disorder, anaesthetised or desensitised areas — hard stop

Skin type eligibility:

• Fitzpatrick Types I-IV only
• Types V-VI: "The efficacy of this device has not been clinically tested in individuals with skin type ranges from V-VI." Neither version should be marketed to darker skin types.

Safety requirements:

• Goggles NOT required — cap is worn on head, no direct eye exposure
• Only use on clean, dry hair/scalp
• One session per 24 hours — do not exceed
• 10-minute session with auto-shutoff
• Light sensitivity test before first use (place cap on inner forearm, 10 min session)
• Individual use only — not for sharing
• Temporary side effect: skin may appear red immediately after use (resolves within 1-2 hours)
• Temporary mild headaches may occur — can be treated with OTC pain relief and hydration
• Stop use if: device feels warm, skin uncomfortably warm, any discomfort

CS routing: Pregnancy, cancer, phlebitis, thrombophlebitis, surgery, Fitzpatrick V-VI questions → hard stop, advise consult healthcare professional. Route all Fitzpatrick V-VI enquiries with explicit note that efficacy is untested in those skin types.

4.10 Red Light Toothbrush

Price: $199 | Tech: Sonic vibration + Red 660nm + NIR 830nm

Version split:

• Non-TH (AU, UK, EU, ROW): Oral hygiene / beauty positioning
• TH (US market): Therapeutic positioning (gum condition claims)

Intended use — non-TH (exact wording):

• "For daily maintenance of oral hygiene"
• "To support healthy teeth and gums as part of a regular brushing routine"
• "To gently stimulate and massage gums with near-infrared and red light and sonic vibration"

Intended use — TH additional (US only):

• "Supports recovery of soft tissues in the oral cavity following dental procedures"
• "Aids in the management of gingival inflammation"
• "Promotes healing of oral soft tissue by stimulating circulation"
• "Helps reduce symptoms associated with mild periodontitis"
• "May reduce gum bleeding and soreness associated with minor gingival conditions"

Permitted claims — non-TH (all markets):

• Daily maintenance of oral hygiene
• Supports healthy teeth and gums
• Gently stimulates and massages gums
• Effective cleaning and gentle gum stimulation
• Enhances oral hygiene and supports gum care

Permitted claims — TH (US only): All non-TH claims plus: gingival inflammation management, soft tissue recovery, post-dental procedure recovery, mild periodontitis, gum bleeding and soreness reduction

Forbidden — non-TH markets:

• Periodontitis
• Gingival inflammation
• Post-dental procedure recovery
• Soft tissue healing
• Gum bleeding as a direct therapeutic claim

Contraindications (both versions — identical):

• Active cancer or cancerous lesion
• Known allergies to light, plastic, or metal
• Photosensitising medications
• Light-induced headache history
• Epilepsy or seizures triggered by light
• Photosensitive disorder

Safety requirements:

• Do not stare at light source — may cause temporary loss of sight
• Do not use on open wounds or infected areas
• Do not use if had recent oral surgery or recovering from infection
• 2-minute smart timer per session; twice-daily use implied
• Light sensitivity test before first use (inner forearm, 10 min)
• Keep out of reach of children

Adverse effects note: "Some users may experience slight gum bleeding during initial use. This usually resolves in a few days. If bleeding continues after two weeks, consult your dentist."

CS routing: Periodontitis, gum disease, post-surgery, or implant questions in non-US markets → use non-TH claims only. Do not escalate to TH claims outside US. Route all complex oral health questions to dental professional.

4.11 Infrared Sauna Blanket

Price: $699 | Tech: Far infrared (FIR) heat | Variants: US 110V / ROW 220V

Intended use (manual): Uses far infrared to increase temperature and create the heat required for a sauna experience.

Permitted claims:

• Soothing full-body warmth for post-workout relaxation and comfort
• Home spa-like relaxation ritual
• Supports wind-down routines and a sense of renewal
• Healthy sweating framed as a natural body process (not detox)
• Stimulates peripheral circulation (only when framed with study reference — not as a direct claim)
• Stimulates sweating / supports healthy perspiration
• Helps relieve tension
• Natural cleansing support
• Benefits of infrared sauna from home
• Science-backed

Forbidden claims:

• Detoxifies / removes toxins or heavy metals
• Burns calories / guarantees weight loss
• Treats chronic pain, inflammation, or any medical condition
• Clinically proven / clinically tested
• "Detox" as a claim — frame sweating as a natural process only

Contraindications (requires doctor approval before use):

• Heart disease or illness
• Broken bones
• Malignancy / cancer
• Post-surgery
• Mental illness
• Metal or body implants (including breast implants)
• Anhidrosis
• Skin disease, reddening, or burns
• Currently pregnant or breastfeeding
• Osteoporosis
• Headache or nausea
• Abnormal blood pressure
• Splanchnic diseases
• Diabetes

Children under 3 must not use. Adults with diminished mental, sensory, or physical capacity must not use unless supervised.

Safety requirements:

• Must wear clothing including socks — "Do not use the Sauna Blanket without clothing and socks on"
• Do not wear metal jewellery
• Do not use with analgesic creams, salves, ointments, or heat-producing topicals (burn risk)
• Temperature range: 25-80°C (77-176°F); start low, increase gradually
• Maximum session: 50 minutes; do not exceed
• Pre-heat for 5 minutes before use
• At high temperatures: place additional towel between skin and blanket
• Do not fold while hot; wait 30 minutes after use before folding
• Do not use alongside any other electrical device
• Voltage/region rule: US content shows 110V variant only; ROW content shows 220V variant only — never cross-market

CS routing: Pregnancy, heart conditions, implants, cancer, blood pressure questions → must not use without doctor approval.

4.12 Infrared PEMF Mat Max

Price: $1,299 | Tech: Far infrared + PEMF + Red 660nm + NIR 850nm | Variants: US 110V / ROW 220V

Intended use: "Wellness device aimed at improving the appearance of skin and general wellness benefits for the user."

Permitted claims (by technology layer):

• PEMF: deep relaxation, grounding, meditation support, calmer headspace
• NIR 850nm: muscle and joint comfort, recovery
• Red 660nm: skin appearance
• Overall: grounded, at-ease feeling; comforting spa-like wellness surface; science-backed

Forbidden claims:

• Treats anxiety, depression, or insomnia
• Heals joints or bones; chronic pain
• Nervous system regulation (as a therapeutic claim)
• Bone or cartilage repair (Bon Charge PEMF is sub-sensory — not strong enough for bone/cartilage outcomes)
• Circulation, detoxification
• Clinically proven / clinically tested

Contraindications (requires doctor approval):

• Pregnant
• Photosensitising drugs
• Suspicious or cancerous lesions
• Recent steroid injection or topical steroids
• Serious medically diagnosed condition
• Heart condition or pacemaker
• Broken bones, malignancy, haemophilia, fever, heat sensitivity
• Alcohol or alcohol abuse
• Post-surgery, mental illness
• Metal or body implants (including breast implants)
• Anhidrosis, skin disease
• Breastfeeding, osteoporosis
• Abnormal blood pressure, splanchnic diseases, diabetes

Hard stop — implanted electrical devices: "Do not use the PEMF appliance when you have implanted electrical devices including pacemakers, cochlear implants, intrathecal pumps etc."

Additional cautions: Overactive adrenal or thyroid glands — use cautiously, seek advice. Active bleeding — control before using PEMF settings. Cardiac rhythm disturbances — seek advice prior to use.

Safety requirements:

• Always wear loose-fitting cotton clothing — do not use without clothing
• No metal jewellery
• No salves, balms, ointments, or heat-producing topicals
• PEMF auto-off after 20 minutes; maximum PEMF session 30 minutes
• FAR infrared: 30-80°C; start low, increase gradually
• Maximum session: 60 minutes
• Do not use on face or heat-sensitive skin
• Photosensitivity test before first use (forearm, 2 min, 1 inch from skin)
• Voltage rule same as Sauna Blanket

CS routing: Pregnancy, pacemaker/implanted devices, cancer, cardiac conditions → hard stop or immediate doctor consultation required.

4.13 Infrared PEMF Mat Demi

Price: $699 | Tech: Far infrared + PEMF + Red 660nm + NIR 850nm | Variants: US 110V / ROW 220V

Identical compliance profile to PEMF Mat Max in all categories — same contraindications, same safety requirements, same permitted/forbidden claims, same session limits, same pregnancy and pacemaker rules.

Key difference from Mat Max: Lower power tier — same safety profile applies.

4.14 Infrared PEMF Wrap

Price: $349 | Tech: Far infrared + PEMF + Red 660nm + NIR 850nm | Variants: US 110V / ROW 220V

Identical compliance profile to PEMF Mat Demi — word-for-word identical contraindications, safety requirements, session limits, and permitted/forbidden claims per user manual.

Positioning note: Portable, localised use (wrap format). Same pacemaker hard stop and pregnancy contraindication apply.

4.15 Infrared PEMF Sauna Dome

Price: $3,349 | Tech: Far infrared + PEMF + Red 660nm + NIR 850nm + crystal layers | Variants: US 110V / ROW 220V

Intended use (exact manual wording): "This general-use wellness product is not intended to prevent, cure, or treat any medical condition."

Permitted claims:

• Deeper spa-like relaxation at home
• Muscle comfort after workouts or busy days
• Relaxed, rest-ready feeling
• 4-in-1 benefits: visible red light / near infrared / far infrared / PEMF
• All-in-one home spa experience
• Science-backed
• Supports restful sleep environment
• Refreshed skin appearance
• Tension reduction

Forbidden claims: Same as PEMF Mats — no treating anxiety/depression/insomnia, no bone/cartilage repair, no detoxification, no circulation as a direct claim.

Contraindications:

• Open or bleeding wounds — hard stop
• Pregnant or planning to become pregnant or breastfeeding — hard stop ("Do not use this product if you are, suspect you may be, are planning to become pregnant, or if you are or plan to begin breastfeeding")
• Cancer or suspected cancerous lesions (including benign tumours) — hard stop
• Epilepsy or seizures triggered by flashing lights — consult physician
• Pre-existing health condition — consult physician
• Steroid medications or injections — consult physician
• Recent surgery, LASIK, skin filler, or breast implants — consult physician
• Light/sunlight sensitivity (Lupus, eczema, light-induced migraines, albinism, rosacea) — consult physician
• Photosensitising medications — consult physician
• St John's Wart, citrus essential oils, antibacterial soap, coal tar — consult physician

Manual gap — pacemakers: The Sauna Dome manual does not explicitly call out pacemakers/implanted electrical devices as a hard stop (unlike the PEMF Mat manuals). However, the Dome has the same PEMF functionality. Treat pacemaker and implanted electrical device users as a hard stop until confirmed by Ana Martins.

Safety requirements:

• Head must remain OUTSIDE the dome at all times during use
• Always use towel insert or wear clothes
• Maximum session: 30 minutes; recommended 20-30 min depending on goals; do not exceed highest heat for more than 10 minutes
• PEMF auto-off after 20 minutes
• Temperature range: 25-90°C upper/lower dome; 25-80°C PEMF mat
• Do not operate while sleeping
• Do not touch inside of dome during operation — gets very hot
• Voltage rule: US 110V / ROW 220V — never cross-market in creative

CS routing: Pregnancy and cancer are hard stops. Pacemaker questions — treat as hard stop and flag gap to Ana Martins.

Section 5 - Market-specific rules

5.1 Default: TGA standard (all markets)

All marketing defaults to TGA compliance — the strictest standard. Covers AU, UK, EU, and global.

5.2 Australia

• Strictest regulatory environment
• Healthcare professionals CANNOT endorse Bon Charge products in AU (TGA Advertising Code prohibition)
• Blue light blocking glasses registered as medical devices in AU — therapeutic claims may be possible in line with registered intended use (confirm per product with Ana Martins before use)
• "Dermatologist tested" forbidden in AU; "Dermatologically tested" may be permissible (confirm with Ana)

5.3 United States

• Healthcare professionals CAN endorse products (FDA does not prohibit the same way TGA does)
• Toothbrush TH: therapeutic claims (gingival inflammation, periodontitis, gum bleeding, post-dental recovery) are permitted — use geographic qualifier in influencer scripts ("for our US audience")
• Red Light Cap TH: referencing Hamilton-Norwood and Ludwig-Savin clinical hair thinning scales is permitted
• Scientific Advisory Board members creating content aligned with their professional platform = more permissible in US
• 510(k) registration number can be referenced on product labels (not "FDA-approved")

5.4 United Kingdom

• MHRA is the regulator — "MHRA Approved" is forbidden and has no compliant substitute
• Diary of a CEO (Steven Bartlett) content: US geographic qualifier in script permits higher-threshold claims in that content

5.5 Gray zone: multi-market influencer content

Content recorded in the US, intended for a US audience, is treated as US-market content even on a global platform — provided a geographic qualifier is included in the script ("for our US friends..."). This is current industry practice and acknowledged as a gray zone. Do not rely on this workaround for AU or UK distribution.

5.6 Voltage/region rule (Sauna Blanket, PEMF Mat Max, PEMF Mat Demi, PEMF Wrap, PEMF Sauna Dome)

• US/Canada creative: show and spec the 110-120V variant (SKU prefix BC-XX-US-)
• UK / EU / AU / ROW creative: show and spec the 220-240V variant (SKU prefix BC-XX-NA-)
• Never mix. Wrong-voltage creative in wrong market = ad rejection and customer complaint risk.

Section 6 - Visual and UGC compliance

6.1 Universal visual rules

Required:

• Red light therapy panels (Mini, Demi, Max, Super Max): show goggles in all visual content
• Red Light Therapy Blanket: show goggles (mandatory per manual)
• Red Light Face Mask: show eye cups in place
• Sauna Blanket: show clothing (loose cotton); show water/hydration nearby; sweating framed as natural
• All red light wearables used on skin: show clean, dry skin
• PEMF Mats/Wrap/Dome: show clothing
• Show correct usage per user manual: correct distance, positioning, and timing

Forbidden:

• Clinical settings (hospital aesthetic, white lab coats, medical equipment)
• Incorrect use (no safety equipment when required, excessive session lengths, incorrect distance)
• Children in product use scenes (exception: blue light glasses for kids — marketed to parents only)
• Before/after photos showing acne, rosacea, or skin condition resolution
• Use on open wounds or injuries
• Glasses worn while driving or operating machinery

6.2 Children

• No children in any product usage content
• Blue light glasses kids range: advertise to parents only ("back-to-school for your kids" framing is acceptable; showing the child wearing glasses in an ad is only permissible in parent-directed contexts)
• No advertising directed at anyone under 18

6.3 UGC structure (required)

1. Hook: Frame a routine problem, not a medical problem
2. Show the ritual: Setup and "this is how I use it" — referenced to user manual
3. Use 1-2 approved benefits only from the per-product permitted claims above
4. Close with disclaimer and disclosure

6.4 Required disclaimer (mandatory for all UGC captions)

"Products are intended for general wellness. Not intended to diagnose, treat, cure, or prevent any disease or medical condition. Always read the instructions and follow the directions for use. Individual results may vary."

6.5 When to include the healthcare professional line

Required when content is educational (physiological effects discussed), when a health-adjacent topic is raised, or when a complex medical condition is alluded to:

"Consult a healthcare professional if you have a medical condition or are undergoing medical treatment."

Not required for simple product/lifestyle image content.

6.6 Disclosure required on all paid/gifted content

"Paid partnership with BON CHARGE" or "gifted" — must be clearly visible, not buried.

Section 7 - UGC pre-publish checklist

Before any UGC goes live:

• Correct product use shown — matches user manual (safety equipment, timing, distance)
• Visuals reflect home or lifestyle setting only — no clinical aesthetic
• Only approved per-product claims used (Section 4)
• No medical terms, conditions, diagnoses, or outcomes
• No restricted keywords: treat, cure, heal, prevent, fix, therapy, treatment, medical-grade, clinically proven, clinically tested, safe
• No guarantees, specific timelines, percentages, or absolute outcomes
• Content is 18+ only — no children shown or targeted
• Required disclaimer included and readable
• Disclosure included (gifted or paid partnership)
• If health-adjacent topic raised: HCP consultation line included

Section 8 - Key edge cases

Section 9 - Escalation

Contact: Dr Ana Martins — ana@boncharge.com

Ana reviews compliance and provides ready-to-use compliant replacement language. She does not just flag issues — she writes the compliant version. Any claim or situation not covered by this document goes to her.

Also in the compliance team: Andrew (CTO), Apoor (Head of Regulatory).

This document to be updated when new products are added to the hero list, when compliance materials are updated, or when Ana Martins provides new guidance. All 15 hero product manuals verified as of 2026-04-25.