Effective Date: October 15, 2026 Version: 1.0 Applies to: All Sellers who offer Products through the Platform.
Article 1: Introduction and Scope
1.1 This Policy states the substantiation duty for every claim a Seller makes about a Product, the claims that are prohibited, and the special rules for pesticide and drug claims. This Policy states compliance duties; this Policy is not legal advice. Where applicable law imposes a stricter standard than this Policy, the law controls.
1.2 Products sold by the Company are "Sold by Pawz Shop." Products sold by a Seller are "Sold by {Seller name}." This Policy governs claims in Seller listings and Seller content; the Company applies the same substantiation standard to first-party claims as a matter of Platform rule.
1.3 If a provision of this Policy conflicts with the Terms of Use, this Policy controls for the subject it governs, subject to Article 1.1. If a provision of this Policy conflicts with the Listing Accuracy Policy, the stricter rule applies. If a provision of this Policy conflicts with the terms of a program in which the Seller participates, the program terms control for that program.
Article 2: Definitions
2.1 The definitions in the Selling Terms of Service apply to this Policy. The following additional terms apply to this Policy only.
2.2 Disease Claim: an assertion that a Product diagnoses, treats, cures, mitigates, or prevents disease.
2.3 Objective Claim: an assertion a Buyer would reasonably understand as a factual statement about a Product, including an efficacy claim, a comparative claim, a health claim, a numerical claim, and an origin or composition claim.
2.4 Structure/Function Claim: an assertion that a Product supports normal structure or function, stated without Disease Claim language.
2.5 Substantiation: competent and reliable evidence, held by the Seller before the claim is published, sufficient to support the claim as stated, including evidence whose conditions: Product, formulation, dose, and period: match the claim.
Article 3: The Substantiation Duty
3.1 Every Objective Claim about a Product shall be substantiated before the claim is published. The Seller holds the evidence and shall produce the evidence on the Company's request, at review, on a Buyer complaint, or on audit. A statement by a supplier is not Substantiation unless the supplier's evidence is in the Seller's file and the Seller has verified that the evidence applies to the Product offered. A claim without Substantiation on file is prohibited, whether or not the claim is in fact true.
3.2 Substantiation shall match the claim. Evidence about an ingredient is not Substantiation for an efficacy claim about the finished Product unless the conditions of the evidence match the Product's use. Evidence that does not address the period, result, or population stated in the claim does not substantiate the claim as stated.
3.3 The substantiation file follows the listing. Where a listing is edited to strengthen a claim, the file shall support the stronger claim before the edit is published. Strengthening a claim without new Substantiation is a new violation.
3.4 The Seller shall keep the substantiation file for each claim for the period the Selling Terms of Service requires for listing records, and shall produce the file under Article 8.
Article 4: Prohibited Claims
4.1 Disease Claims for Products that are not drugs. A pet food, supplement, or grooming Product shall not carry a Disease Claim, including a claim that the Product treats, cures, heals, or prevents a condition, unless the Product is an approved drug sold under the Prescription Products Policy (Prescription Products Policy (Sellers)) or an EPA-registered pesticide sold under the Flea, Tick and Pesticide Products Policy with the claim stated on the registered label. A Product offered as pet food or a treat is additionally subject to the labeling regime stated in AAFCO Pet Food Labeling; a Disease Claim does not become permissible by reason of food labeling compliance.
4.2 Endorsement claims. A claim that a Product is recommended, approved, or formulated by a veterinarian requires: (a) identification of the veterinarian or veterinarians, or of a bona fide survey, behind the claim; (b) the basis of the endorsement, including what was evaluated and whether the evaluation addressed the Product or the category; and (c) no material misrepresentation of the scope of the endorsement. A material connection behind an endorsement, including payment, a commissioned survey, or a licensing arrangement, shall be disclosed in the listing. An undisclosed paid endorsement is a claim violation and a deceptive practice.
4.3 "Natural," "organic," and similar terms. A term in this Article shall meet the applicable regulatory definition for the Product category. "Organic" on pet food invokes the applicable organic standard; a Product that does not meet the standard shall not carry the term. Where no regulatory definition exists for a term, including "holistic," the term shall not imply a regulated meaning, and shall not be paired with imagery or copy that manufactures a regulated meaning.
4.4 Before-and-after imagery. Before-and-after imagery that implies disease treatment is prohibited for a Product that is not a drug, in images under the Product Image Policy, in descriptions, and in enhanced content. The prohibition covers the implication the imagery creates, not only a caption that states the claim.
4.5 Origin claims. An origin claim, including "Made in USA," is subject to the applicable origin standard: "Made in USA" states that all or virtually all of the Product is of United States origin. "Assembled in USA," "designed in USA," and "packaged in USA" are different claims with different standards; the Seller shall state the claim that is true.
4.6 Absolute safety claims. A claim of absolute safety: including "100% safe," "no side effects," an unqualified "non-toxic" claim for a Product that is of low toxicity, or "chemical-free": requires Substantiation to the same standard as an efficacy claim, and an unqualified safety claim is prohibited where the Seller cannot substantiate safety without qualification.
Article 5: Pesticide and Drug Claims
5.1 Verbatim-label rule for pesticides. An efficacy claim for a flea, tick, or pesticide Product shall match the EPA-registered label verbatim. The Seller shall not paraphrase, extend, or combine registered label statements into a stronger claim. An off-label efficacy claim is a violation of the regime stated in EPA FIFRA Pesticide Registration: the listing is suppressed on detection, the finding is a serious violation, and regulatory exposure for the claim rests with the Seller. Pesticide Products are governed additionally by the Flea, Tick and Pesticide Products Policy.
5.2 Drug claims. A claim that positions a Product as a drug may appear only on a Product sold as a drug under the Prescription Products Policy (Prescription Products Policy (Sellers)), and only as the approved labeling states the claim. A supplement listing that borrows a drug's indication states a Disease Claim for a Product that is not a drug and is governed by Article 4.1.
Article 6: Where Claims Appear
6.1 This Policy follows the claim across every surface, including the title, the description, images and infographics, enhanced content, variant names, backend search terms, a Seller's answers in a question-and-answer facility, and review responses. A prohibited claim does not become permitted by reason of the surface on which the claim appears.
6.2 Implication. A claim is made where listing copy implies the claim, even if the copy does not state the claim in terms. Copy that presents a Product as a solution for a condition, on a Product that is not a drug, states an implied Disease Claim.
6.3 Testimonials. A testimonial the Seller publishes in a listing is the Seller's claim, subject to this Policy in full and to the testimonial rules in the Product Review Policy for Sellers. A Buyer review that contains a Disease Claim does not authorize the Seller to repeat the claim in the listing.
6.4 Where a prohibited claim has caused Buyer harm, including reliance on a supplement in place of treatment, the matter is additionally addressed under the Return and Refund Policy: Sellers (Return and Refund Policy — Sellers) for return and refund exposure and under Article 8 for the measure applied.
Article 7: Liability
7.1 Exclusion of certain damages. To the fullest extent permitted by law, neither party is liable to the other for indirect, incidental, special, punitive, or consequential damages, or for lost profits, lost revenue, or loss of goodwill, arising out of or relating to this Policy, even if the party has been advised of the possibility of those damages.
7.2 Cap. To the fullest extent permitted by law, the Company's total liability arising out of or relating to this Policy shall not exceed the greater of (a) the amounts the Seller paid to the Company under this Policy in the twelve months before the event giving rise to the claim, or (b) one hundred dollars ($100).
7.3 Carve-outs. This Article does not limit (a) a party's indemnification obligations under this Policy; (b) liability for fraud or willful misconduct; (c) amounts the Seller owes for Orders, fees, chargebacks, or refunds under the Company's documents; or (d) liability that cannot be limited under applicable law.
7.4 Essential purpose. The parties agree that this Article allocates risk between them, that it is an essential part of the basis of their bargain, and that it applies even if a limited remedy fails of its essential purpose.
Article 8: Indemnification
8.1 Duty. The Seller shall indemnify, defend, and hold harmless the Company and its members, managers, employees, and agents from and against every claim, demand, action, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) arising out of or relating to: (a) the Seller's breach of this Policy; (b) the Seller's Products, Services, listings, or content, including product liability claims, intellectual property infringement claims, and product recall costs; (c) the Seller's violation of any law or of the rights of any person; and (d) taxes for which the Seller is responsible under the Company's documents.
8.2 Procedure. The Company shall give prompt written notice of a claim under this Article. The Seller shall control the defense with counsel reasonably acceptable to the Company. The Company may participate in the defense at its own expense. The Seller shall not settle a claim in a manner that imposes any obligation or restriction on the Company, or that does not release the Company fully, without the Company's prior written consent.
8.3 Survival. This Article survives the termination of this Policy.
Article 9: Enforcement and Appeals
9.1 Investigation. The Company may investigate any suspected violation of this Policy. The Seller shall cooperate with an investigation and shall produce the records this Policy requires the Seller to keep, including the substantiation file for a claim under investigation.
9.2 Notice. If the Company determines that the Seller has violated this Policy, the Company shall give written notice stating the provision violated and the facts relied on, except where notice would compromise an investigation of fraud, a safety risk, or a legal obligation.
9.3 Opportunity to cure. Where a violation is capable of cure, the Seller has ten (10) business days from notice to cure it and to confirm the cure in writing, by removing the claim or by producing Substantiation that supports the claim as stated. No cure period applies to fraud, counterfeiting, a risk to the safety of a person or an animal, unlawful conduct, a Disease Claim for a Product that is not a drug, an off-label pesticide claim, or a violation that by its nature cannot be cured; a listing carrying such a claim may be suppressed on detection.
9.4 Measures. If a violation is established and is not cured within the period allowed, the Company may, proportionate to the violation: (a) issue a written warning; (b) remove or suppress a listing or content until the claim is removed or substantiated; (c) cancel an Order; (d) suspend the Account or a program participation, in whole or in part, including an account-level restriction for a serious violation; (e) terminate this Policy and the Account; and (f) exercise any other right or remedy available under the Company's documents or at law.
9.5 Disbursement hold. The Company may hold disbursements to the Seller while an investigation under this Article is pending, and shall release amounts not required to satisfy the Seller's obligations when the investigation closes.
9.6 Appeal. The Seller may appeal a measure under this Article by written notice to legal@aapawz.com within thirty (30) days of the measure, stating the grounds and attaching the records relied on, including the substantiation file relied on. The appeal is decided by a person who did not make the original decision. The Company's decision on appeal is final. A measure remains in effect during an appeal unless the Company directs otherwise in writing.
9.7 No waiver by delay. The Company's delay in acting on a violation is not a waiver of the violation or of any later violation of the same kind.
Article 10: Term and Termination
10.1 Term. This Policy takes effect when the Seller is accepted to offer Products through the Platform and continues until terminated under this Article.
10.2 Termination by the Company. The Company may terminate this Policy and the Account on thirty (30) days' written notice for any reason, and immediately on written notice if the Seller materially breaches this Policy, engages in fraud, or becomes ineligible to participate.
10.3 Termination by the Seller. The Seller may terminate this Policy on thirty (30) days' written notice to support@aapawz.com, provided the Seller has no Order or investigation outstanding.
10.4 Effect of termination. On termination: (a) the rights granted under this Policy end; (b) obligations that arose before termination: including payment, refund, chargeback, record-keeping, and indemnification obligations: survive until satisfied; and (c) the Company shall disburse amounts owed, less amounts the Company may set off under the Company's documents, within thirty (30) days, except amounts held in connection with an open investigation or dispute.
10.5 Survival. The Definitions, Liability, Indemnification, Enforcement and Appeals (for measures taken before termination), Dispute Resolution, and General Provisions Articles survive termination.
Article 11: Dispute Resolution
11.1 Any dispute arising out of or relating to this Policy, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this Policy by reference.
Article 12: General Provisions
12.1 Amendments. The Company may amend this Policy by posting the amended Policy in the Document Center and giving notice to the Seller at the email address in the Account. An amendment that materially increases the Seller's fees or obligations takes effect thirty (30) days after notice; other amendments take effect on posting. Continued use of the Platform after the effective date of an amendment is acceptance of it. A Seller that does not accept an amendment may terminate under Article 10 before the amendment takes effect.
12.2 Notices. Legal notices under this Policy shall be sent to legal@aapawz.com. Operational notices and all other communications shall be sent to support@aapawz.com. A notice to the Company is effective when the Company acknowledges receipt or, for email, one business day after sending, whichever is earlier. Notices to the Seller are effective when sent to the email address in the Account or posted to the Account's notice facility in the portal, whichever occurs first. The Seller shall keep the email address in the Account current.
12.3 Governing law. This Policy is governed by the laws of the State of Tennessee, without regard to its conflict-of-laws rules. Subject to the Dispute Resolution Policy, any proceeding arising out of this Policy shall be brought in the state or federal courts located in Shelby County, Tennessee, and the parties consent to personal jurisdiction there.
12.4 Severability. If any provision of this Policy is held unenforceable, the provision shall be enforced to the fullest extent permitted, and the remaining provisions continue in full effect.
12.5 Entire agreement. This Policy, together with the documents it incorporates by reference, is the entire agreement between the Company and the Seller for the subject it governs and supersedes every prior or contemporaneous statement, communication, or agreement on that subject, whether written or oral.
12.6 Assignment. The Seller shall not assign this Policy or any right or obligation under it without the Company's prior written consent, and an assignment without consent is void. The Company may assign this Policy to an affiliate or in connection with a sale of all or part of its business, on notice to the Seller.
12.7 Waiver. A waiver of any provision of this Policy is effective only in writing and only for the instance stated. No waiver is a waiver of any other provision or instance.
12.8 Interpretation. Headings are for convenience only. "Including" means "including without limitation." This Policy shall not be construed against a party as its drafter. The English-language text controls over any translation.
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