Josh Zwagil appears to cross both these lines when he claims in an “opportunity” video that those “looking to go all in and build a full-time income” can do so with his MLM, without disclosing what the company’s Policies and Procedures make abundantly clear — which is that most distributors spend more on products than they earn in the compensation plan (See next section). Top HempWorx distributor Judy Stallings, who has been introduced at conventions as the “first-ever 250K affiliate,” has also used inappropriate income claims to bring people into the MLM, writing on her Facebook page last December:
Under the historic 2018 Farm Bill, hemp companies should be able to advertise like other agricultural producers and manufacturers. But many businesses say they still face hurdles, especially with digital marketing. A good example is Evo Hemp, a Boulder, Colorado-based hemp food company. “The Farm Bill is opening the doors to have the conversation with […]
We do not make any health claims about our products at Hemp Worx. Before taking our products, it’s wise to check with your physician or medical doctor. It is especially important for people who are: pregnant, chronically ill, elderly, under 18, taking prescription or over the counter medicines. None of the information on our website is intended to be an enticement to purchase and may not be construed as medical advice or instruction.
In June 2018, the U.S. Senate passed its 2018 Farm Bill and in December 2018, President Trump signed the bill into law to make hemp legal for the first time since the 1930s. The bill removes hemp from the Controlled Substances Act, effectively legalizing the plant federally and allowing it to be grown, processed, and sold as an agricultural commodity. Individual states will be authorized to draft their own regulations governing hemp cultivation.
As you comb through the web pages, it’s clear the product is meant for a multi-level marketing scheme.  Many of these companies do not expect anyone to actually use the product.  They just  want people who will buy it in hopes of selling it to someone else.  One previous potential customer has said he could not buy the product, as the company demanded a referral.  This means multi-level marketing might be their main business.  This can lead to problems getting the product for regular consumers, though they do have an option to sell directly to the consumer as well on the website.

HempWorx CBD is an interesting brand that has no issue with transparency in terms of how they operate as a business, and where they source their raw hemp plant material from. Also, one of the main things that stands out to me as that they’re one of the only companies I know of that offers specific dosing guidelines for a range of serious medical conditions. This is a bit odd, however, as they also make it clear that CBD is not approved by the FDA as a medicine, and thus none of their products are designed to “treat, cure, or prevent” any disease.
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