Bulletproof
Facts-only compliance record. Every entry is source-backed and dated.
Event Timeline
Prop 65 settlement: $30,000 for alleged lead in Bulletproof Greens
Keep America Safe and Beautiful (KASB) and Bulletproof 360, Inc. entered an out-of-court settlement over alleged lead in Bulletproof Greens sold in California without a Proposition 65 warning. The Attorney General's record (AG No. 2023-00984) dates the settlement June 25, 2024, names the case KASB v. Bulletproof 360, Inc., and states it was not submitted to a court. The covered product is Bulletproof Greens, including "Bulletproof Greens – Daily Greens for Body and Mind," UPC 8 15709 02561 8. KASB served a 60-day notice on April 12, 2023. Bulletproof denies the allegations, and the agreement states it is not an admission of any violation. Bulletproof agrees to pay $30,000: a $3,000 civil penalty ($2,250 to OEHHA and $750 to KASB) and $27,000 for KASB's attorneys' fees, expert and investigation fees, and costs, due on or before June 28, 2024. Beginning 60 days after the effective date, Bulletproof is permanently enjoined from manufacturing for sale in California, distributing into California, or directly selling in California any covered product that exceeds 0.5 micrograms of lead per day unless it carries a specified warning. The warning must include the phrase "cancer and" if exposure is greater than 15 micrograms of lead per day. The signature page is signed for Bulletproof 360, Inc. by Lance Nguyen, Chief Operations Officer, and shows execution dates of June 24, 2024 and June 25, 2024. This entry uses the Attorney General's reported settlement date.
FTC warning letter: Dave Asprey COVID-19 prevention and treatment claims
On June 19, 2020, FTC staff sent a warning letter to Dave Asprey, c/o Bulletproof 360, Inc., 1012 1st Avenue, Suite 400, Seattle, Washington 98104, by email to support@bulletproofexec.com. The letter says staff reviewed https://daveasprey.com/ on June 15, 2020, and determined he was unlawfully advertising that certain products prevent or treat COVID-19. The examples come from a blog post titled "What I Do to Protect Myself From Coronavirus, and How I Plan to Kick It if I Get It," and include andrographis; sage, oregano, and bay leaf extracts; a fiber blend he wrote he developed for Bulletproof; vitamin D3, zinc, and magnesium; an Unfair Advantage formula containing PQQ and CoQ10; a high-potency omega-3 formula he wrote he developed for Bulletproof; black cumin seed oil; hydroxytyrosol; broccoli sprouts or sulforaphane; and L-glutamine. Several cited links are Amazon short links, not bulletproof.com product pages. The letter states that advertising a product can prevent, treat, or cure human disease without competent and reliable scientific evidence violates the FTC Act, that no such study was then known for the products identified, and that the claims must stop immediately. It asks for a description of specific actions within 48 hours, sent to James E. Elliott. Dama J. Brown, Regional Director, Southwest Region, signed the letter. It is a staff warning letter, not a filed complaint and not a monetary order.
FDA warning letter MARCS-CMS 593246: CGMP adulteration and separate unapproved-drug claims
On March 20, 2020, FDA issued warning letter MARCS-CMS 593246 to Bulletproof 360, Inc. after an inspection on August 12–15, 20, 22, 28 and September 3 and 6, 2019. The letter keeps two violations distinct. CGMP adulteration: Chocolate Collagen Protein and Vanilla Collagen Protein are adulterated dietary supplements under FD&C Act section 402(g)(1) because they were prepared, packed, or held under conditions that do not meet dietary-supplement CGMP (21 CFR Part 111). FDA cited failure to establish component specifications under 21 CFR 111.70(b), including an identity specification for bovine hydrolyzed collagen protein used in those two products that was not sufficient to distinguish it from hydrolyzed collagen from other animal sources. Unapproved-drug claims: a March 2020 review of www.bulletproof.com found Curcumin Max and Mitosweet ordered from the site and marketed for disease uses, so FDA determined those products are unapproved new drugs under section 505(a) and misbranded drugs under section 502(f)(1). The collagen findings are the CGMP adulteration; the Curcumin Max and Mitosweet findings are the drug claims.
Class I voluntary recall for undeclared milk (Unflavored Collagen Protein)
Bulletproof 360, Inc. initiated a voluntary Class I recall (FDA event_id 79018; recall number F-0774-2018) on 2018-01-23 covering Bulletproof Unflavored Collagen Protein (16-oz bag, UPC 8 15709 02115 3, lot 1017088, EXP 03/19) because of undeclared milk. FDA reason text: "Bulletproof Collagen Protein is recalled due to undeclared milk. The actual product inside the package is whey (milk) protein but mis-labeled as collagen protein." The FDA company announcement is dated 2018-01-25; this entry uses the openFDA recall initiation date. Recall terminated 2018-04-20.
Prop 65 consent judgment: $65,000 for cadmium in Bulletproof Chocolate Powder
Erika McCartney v. Bulletproof Digital, Inc., Alameda County Superior Court No. RG16825738. The stipulated consent judgment identifies the defendant as Bulletproof 360, Inc., formerly known as Bulletproof Digital, Inc., a Delaware corporation, and the covered product as Bulletproof Chocolate Powder. A 60-day notice (AG No. 2016-00400) was served on or about May 4, 2016, alleging the product contains cadmium, listed under Proposition 65 as causing birth defects or other reproductive harm, and was sold in California without a clear and reasonable warning. The complaint was filed August 2, 2016. The Attorney General's record reports the settlement on March 28, 2017, and dates the judgment June 20, 2017. The consent judgment requires a total payment of $65,000: $20,000 in civil penalties under Health & Safety Code section 25249.7(b) ($15,000 to OEHHA, $4,000 to McCartney, and $1,000 to the California Chapter of the March of Dimes), payable within 30 days of the effective date, plus $45,000 to counsel Robert B. Hancock for attorneys' fees, costs, and investigation and litigation expenses, in two payments of $22,500 at 60 and 90 days. Beginning on the effective date, defined as the date the consent judgment is entered, Bulletproof is permanently enjoined from offering the covered product for sale to a California consumer, directly selling it to a California consumer, or distributing it into California without a Proposition 65 warning. The judgment states it settles disputed claims and is not an admission of any violation. Bulletproof generally denied the allegations.
Class I voluntary recall for potential Listeria (Collagen Protein Bars and Bites)
Bulletproof 360, Inc. initiated a voluntary Class I recall (FDA event_id 77548; recall numbers F-2436-2017, F-2437-2017, F-2438-2017, F-2439-2017, and F-2440-2017) on 2017-06-14 covering five Collagen Protein Bar and Bite products — Fudge Brownie bar, Fudge Brownie bite, Lemon Cookie bar, Vanilla Shortbread bar, and Vanilla Shortbread bite — because they had the potential to be contaminated with Listeria monocytogenes. Recall terminated 2017-11-08.