MAKE Wellness (Upper Level Health, LLC)
The peptide branding is the hook and the regulatory scare - but the actual actives are oral plant and yeast hydrolysates that carry no unapproved-drug exposure. The problem is $1,200 a year of subscription against average earnings of $86.82 below Leader rank, where the median was $3.
Free to join, no injectables, no scheduled compounds and a real buyback - attached to a subscription that costs about fourteen times what the average affiliate below Leader rank earns.
Can you actually make money with MAKE Wellness?
No, and the company's own disclosure is where that lands. Average annual earnings for the 93.458% of affiliates below Leader rank were $86.82, and the median was $3.00. Some 44.29% were paid nothing at all in 2025, the year the company reported $102 million of revenue, and only 6.54% reached Leader in 2025, the rank at which the plan starts paying meaningfully. Set that beside the $100 a month that unlocks the product credits the plan is built around, and the ratio against that average is roughly fourteen dollars out for one back.
The retail-looking part of the plan does not require a retail sale. Personal orders count toward Circle Sales only from Rising Affiliate, which reads like a safeguard, but orders placed by enrolled Direct Affiliates count alongside orders placed by customers, up to 500 of volume per Direct Affiliate a month, so every customer-flavoured requirement can be satisfied inside the network. Part of what is paid also arrives as store credit rather than cash: with a $100 monthly subscription, Circle Sales titles from Premier Affiliate up earn $50 to $200 a month of credit, redeemable only against more product.
Now the part that cuts against the headline, and it matters. The peptide branding invites an unapproved-drug conclusion and the products do not support it. Every SKU is oral, sachet or capsule or gummy, and every peptide in the range is a plant or yeast hydrolysate. None of the compounds on FDA's 503A Category 2 list appears in any formula. Entry is genuinely free with no kit and no tool fee, unopened resalable product comes back at 90% within twelve months, paid advertising is banned apart from generic opportunity ads, and no regulator has acted against the company.
genuinely free to enroll - but $100/month of personal subscription unlocks the product credits the plan is built around
- A customer-volume gate that customers have to satisfy. While orders from enrolled Direct Affiliates count toward Circle Sales alongside orders from customers, the volume requirements measure nothing that reaches a non-participant.
- Compensation paid in money rather than in credit against more product. Store credit buys more of what an affiliate is already buying; it does not pay a bill and it never leaves the ecosystem.
- A compensation plan that stops moving. It reached its fourth revision by March 2025, was replaced by a new ClearPath plan in June 2026, and the launch-era bonuses have expired, so nobody who joined on the original slides is operating under the economics they were shown.
- Earnings that clear the subscription. The company publishes an $86.82 average and a $3.00 median below Leader rank against $1,200 a year, and it deserves credit for publishing it, but that is the number this file turns on.
That call is computed, not chosen - the rule reads three of the nine published dimension scores and is printed on the methodology page. It describes this company's plan and the figures it publishes about the people already in it. It is not a prediction about you, and nothing on this site is advice.
Legal status
LEGAL - no FTC action, state attorney general action, consent order, FDA warning letter, import alert or class action against the company or the trading entity could be located. The file contains one self-regulatory earnings-claim case (DSSRC #204-2025, closed 20 March 2025) which the company resolved by removing every challenged claim. Separately, litigation between the founders and their former employer was filed in Utah in October 2023 with no located disposition; that is a dispute between private parties, not a regulatory matter.
Confidence: Medium
Primary sources fetched directly where possible. Everything we could not verify is listed at the bottom of this page by name.
Follow the money
Graded against the ClearPath Compensation Document (June 2026, V5). A Utah company selling oral peptide-branded supplements through independent affiliates on a two-part plan of personal Circle Sales and team commissions, launched in late 2024 by a founding team drawn mainly from two earlier direct-selling companies.
Deal with the peptide question first, because it is the reason most people arrive at this page and the honest answer is not the alarming one. Every product in the range is taken by mouth - sachets, capsules and gummies - and the peptides are plant and yeast hydrolysates, chiefly from fava beans and brewer’s yeast, including a patented branded ingredient supplied by a named ingredient company, with self-affirmed GRAS status and published clinical work behind it. None of the compounds on FDA’s Category 2 bulk-substances list appear anywhere in the range, and none of the research-chemical peptides that attract enforcement attention appear either. There is no injectable, no scheduled substance and no unapproved-new-drug exposure. That finding cuts strongly in the company’s favor and it is worth being unambiguous about it.
The compensation structure has real limits. Under the current ClearPath plan, Circle Sales pays 10% to 40% on personal-circle volume and team pay falls from 10% to 1% of Pay Volume as titles rise, with no binary legs and no matching bonus, and an affiliate’s own orders count toward Circle Sales only from Rising Affiliate and only up to 500 of volume a month. Entry is free and it is really free - no kit, no enrollment fee, no mandatory website charge. There is a 90% buyback on unopened product within twelve months and a three-day cooling-off period. Paid advertising is banned apart from generic opportunity ads, which is a real control on the claim inflation that generates most of this industry’s regulator files.
Then read the disclosure the company publishes itself. Some 93.458% of affiliates never reach Leader rank, and the average annual earnings of that group are $86.82, with a median of $3.00. Just over 44% earned nothing at all in 2025. Against that sits the $100-a-month personal subscription required to unlock the product credits the plan is built around - $1,200 a year - and a structure in which part of what is earned, up to $200 a month, arrives as store credit rather than cash. The single defect that ties the plan back to the category norm is quieter: enrolled Direct Affiliate orders count toward Circle Sales alongside customer orders, up to 500 of volume per Direct Affiliate a month, so every retail-flavoured requirement can be satisfied without one sale ever reaching a non-participant.
Where affiliates landed in 2025
MAKE Wellness’s own published earnings disclosure. Percentages of the affiliates the disclosure counts (those who enrolled, enrolled someone or earned in the prior 12 months); earnings are gross, before the expenses the disclosure itself lists.
| Product | Price | Pays |
|---|---|---|
| Affiliate enrollment Genuinely free: no kit, no enrollment fee, no mandatory website or tool charge in the policies. During the 2024 prelaunch a personal purchase was originally required; that condition was withdrawn after public criticism. |
$0 — |
— |
| Personal subscription to unlock credits The functional cost of the business - $1,200 a year. It is not required to remain an affiliate; it is required to be eligible for product credit, which Circle Sales titles earn at $50 to $200 a month from Premier Affiliate up and which is scrip rather than cash. |
$100+/mo recurring |
— |
| CALM Was $49.99 in November 2024 - a 20% increase inside eighteen months of launch. |
$59.99 per 30 servings |
Circle Sales 10-40% |
| HYDRATED Was $49.99. The cheapest entry to the range. |
$54.99 per 30 servings |
Circle Sales 10-40% |
| FOCUSED Was $59.99 - up 16.7%. |
$69.99 per 30 servings |
Circle Sales 10-40% |
| ENERGIZED Was $79.99. Marketed as a jitter-free stimulant alternative. |
$89.99 per 30 servings |
Circle Sales 10-40% |
| LEAN Was $89.99. The weight-adjacent SKU, and the one most likely to attract claim problems in the field. |
$99.99 per 30 servings |
Circle Sales 10-40% |
| FIT Was $119.99. Carries the patented fava-bean hydrolysate, which has published clinical work at 2.4 grams a day; a proprietary blend means the label does not show whether FIT delivers that dose. Still the strongest evidence position in the range. |
$129.99 per 30 servings |
Circle Sales 10-40% |
Who runs it, and what they ran before
A top field leader at his previous direct-selling company, from which he was terminated on 12 October 2023. That company then sued him and his holding entity in the Fourth District Court of Utah, alleging a deliberate effort to solicit its salesforce and use its proprietary information to build a competitor; he had sued first, claiming he was instructed to distribute the material at issue. No disposition of either action could be located, and no allegation in either has been proven. His former company announced its closure on 11 April 2025, with no notice to its distributors, and the rights to its products were sold about six weeks later - MAKE Wellness’s early field was drawn substantially from that same population.
Senior vice president of global sales and marketing at the same former employer, terminated on the same day as Prince and named in its complaint as a co-conspirator rather than as a defendant. As with Prince, nothing has been proven and no outcome could be located.
Chief executive of a large listed direct-selling company from 2003 to December 2016. During that tenure the company settled a securities class action for $47 million arising from allegations that it operated an illegal pyramid scheme in China, was fined by Chinese authorities in 2014, and in September 2016 paid $765,688 to the SEC - disgorgement, interest and a civil penalty - to resolve books-and-records and internal-controls charges arising from a donation made to a charity connected to a senior official during a Chinese regulatory investigation. The company neither admitted nor denied the SEC findings, and the SEC order named only the company.
Whitehead is a former chief executive of one large direct-selling brand and a former president of another, with board roles at industry trade bodies. Bartlett spent roughly thirty years in nutritional science at two established supplement companies. The team is genuinely experienced - that is the honest read, and it cuts both ways. They know how to build a nine-figure direct-selling business in eighteen months, and their collective résumé also includes a company that vanished overnight and a company that paid $47 million over pyramid allegations abroad.
Registered address
Utah, USA
The trading entity is Upper Level Health, LLC, a Utah limited liability company. Public records are thin and partly inconsistent - the BBB profile describes the business as an S corporation while the entity name is an LLC, and no Utah filing number could be confirmed. No audited accounts exist. The 2025 revenue figure of roughly $102 million is a company statement corroborated by a trade ranking; the widely repeated $20 million figure for 2024, which makes the growth story, is a third-party estimate rather than a reported number.
The veteran's checklist
Eight questions that decide whether this is a business or a transfer mechanism. Same eight, every review.
| Question | Answer |
|---|---|
| Who legally owns it? |
WATCH
Upper Level Health, LLC, a Utah limited liability company with a business start date of 23 April 2024. No audited accounts; public records are thin and partly inconsistent.
|
| Are the products actually regulated peptides? |
OK
No. Every SKU is oral and every peptide in the range is a plant or yeast hydrolysate. No FDA Category 2 compound and no research-chemical peptide appears in any formula, and there is no FDA letter in the file.
|
| What does it really cost? |
WATCH
$0 to enroll, genuinely - no kit, no fee, no mandatory tool charge. The functional cost is the voluntary $100-a-month subscription that unlocks product credits: $1,200 a year.
|
| Published income disclosure? |
CONCERN
Yes, and it is specific. 44.29% of affiliates earned nothing in 2025; 93.458% never reached Leader rank; the average for that group was $86.82 for the year and the median $3.00, gross of expenses.
|
| Regulatory action against the company? |
OK
None located - no FTC, no state attorney general, no consent order, no FDA warning letter, no class action. One self-regulatory earnings-claim case closed in March 2025 after all seven challenged claims were removed.
|
| Is there a monthly purchase requirement? |
CONCERN
Not to remain an affiliate. But $100 a month is required to be eligible for product credits, and part of compensation, up to $200 a month, is paid in credit rather than cash.
|
| Can you get your money back? |
OK
Yes - 90% on unopened resalable product returned within twelve months, shipping excluded, plus a three-day cooling-off period for new enrollees.
|
| Merchant play or miner play? |
WATCH
Mixed, and better than most. The plan has no binary - but its volume gates can be satisfied with orders from enrolled affiliates, and paid ads (apart from generic opportunity ads) and marketplaces are both banned, leaving your own social graph as the only channel.
|
What has to be true for you to get paid
| To cover | You need |
|---|---|
| Hold an affiliate account | $0 no enrollment fee, no kit, no mandatory tool charge |
| Be eligible for product credits | $100/mo personal subscription order = $1,200 a year |
| Open team commissions | Premier Affiliate, 2,000 Circle Sales volume a month though enrolled Direct Affiliate orders count toward it, up to 500 of volume each a month |
| Cover the $1,200 subscription from commissions | ~14x the average outcome against $86.82 average annual earnings below Leader rank (median $3.00) |
Read this twice
The honest framing of this business is that its cost structure is better than the category and its outcomes are not. Entry is genuinely $0 - no kit, no fee, no mandatory website - and there is no contractual monthly quota to remain an affiliate. Everything hinges on one voluntary decision: whether to run the $100-a-month personal subscription that makes you eligible for up to $200 a month of product credit. That framing is deliberately attractive, and it deserves two pieces of scrutiny. The first is that the credit is scrip. It buys more product; it does not pay rent, and it does not appear in a bank account. The second is the disclosure. MAKE Wellness publishes the number itself: the average annual earnings of the 93.458% of affiliates below Leader rank is $86.82, the median is $3.00, and 44.29% earned nothing at all. Against $1,200 of subscription, the average participant below Leader is running roughly fourteen dollars out for every dollar in, before events or anything else - and the disclosure explicitly lists expenses such as events as not deducted. There is a real caveat in the company’s favor: this is a purchase, not a fee, and someone who would take the supplements regardless is only paying the price premium rather than the whole sum. But the volume gates have a hole in them - orders from enrolled Direct Affiliates count toward Circle Sales alongside orders from customers, up to 500 of volume per Direct Affiliate a month - so the requirements that read like a retail safeguard can be satisfied entirely inside the network.
Run your own numbers
Drag the sliders. Nothing here is stored or sent.
About $8.42 a month per customer: 10% Circle Sales on one product a month at the average list price of the six products, $84.16 (our arithmetic: $504.94 / 6), assuming volume equals the price paid, as the March 2025 revision’s worked example did. ClearPath pays 10% below 500 of monthly volume, 12% from 500 (Rising Affiliate, $100 minimum), 14% from 1,000 (Sr. Affiliate, $200 minimum) and 20% from 2,000 (Premier Affiliate, $500 minimum), so a flat rate understates the step-ups: eight such customers, 673 of volume, earn the $100 Rising minimum where this calculator shows about $67 (our arithmetic). Cost is the $100 personal subscription, which is needed only to be eligible for product credits, paid from Premier Affiliate up - it is not required to hold an account, so set it aside mentally if you stay on the free tier. Paid advertising is banned apart from generic opportunity ads, so the ad-spend slider should stay at zero. Published 2025 average for the 93.458% below Leader rank: $86.82 a year; the median was $3.00. Your own subscription cost of $100/mo is included.
What it costs to replace this yourself
The comparison that matters here is not against injectable peptides - there are none in this range - but against the same class of oral branded-ingredient supplements sold without a compensation plan attached. Comparator prices are open-market ranges for products carrying equivalent branded actives at equivalent doses, presented as bands because formulations differ.
| What they sell you | What you'd use instead | Your cost |
|---|---|---|
| FIT - $129.99 for 30 servings | Branded fava-bean peptide hydrolysate at a clinical dose | ~$35-60 |
| LEAN - $99.99 for 30 servings | Open-market metabolic support with disclosed actives | ~$25-45 |
| ENERGIZED - $89.99 for 30 servings | Caffeine-free energy formulation, disclosed amounts | ~$20-35 |
| CALM - $59.99 for 30 servings | Magnesium glycinate plus adaptogen blend | ~$15-30 |
| HYDRATED - $54.99 for 30 servings | Electrolyte and amino sachets, comparable count | ~$18-30 |
| Three-product stack on subscription - ~$260/mo | Equivalent open-market stack | ~$70-130 |
| $100/mo subscription to unlock product credits | Buying only what you would take anyway | $0-60 |
| Total as sold ~$1,200-3,120 a year |
Total, built yourself ~$400-950 a year |
Price-to-value
Roughly a two-to-three-times premium, which is moderate by the standards of this category rather than extreme. What you are buying at the top of that band is a genuine branded ingredient with published clinical work behind it - that is real, and better documented than most. What you are not buying is independent evidence on the finished products, because proprietary blends prevent you from checking what is in the other SKUs, and the sleep product’s supporting data is described as an internal study. The subscription is the line that decides everything: if you would take these supplements anyway, the premium is the whole cost. If you are buying them to stay eligible for credits, the premium is the least of it.
Three operators, five horizons
Probability of cumulative net profit
Hover any point for median, top decile and bottom quartile.
Free-tier affiliate
enrolls at $0, no subscription, shares occasionally
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 34% | $0 |
| 6 mo | 33% | $0 |
| 1 yr | 32% | +$10 |
| 3 yr | 30% | +$25 |
| 5 yr | 29% | +$40 |
Subscribed builder
$100/mo subscription, part-time, warm market and organic social
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 9% | −$280 |
| 6 mo | 12% | −$540 |
| 1 yr | 15% | −$1,000 |
| 3 yr | 18% | −$2,900 |
| 5 yr | 19% | −$4,600 |
Full-time affiliate
30+ hrs/wk, multi-product stack, events, no paid ads permitted
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 4% | −$900 |
| 6 mo | 8% | −$1,700 |
| 1 yr | 12% | −$3,000 |
| 3 yr | 16% | −$7,400 |
| 5 yr | 17% | −$11,000 |
Methodology note. ANCHORED to MAKE Wellness’s own 2025 earnings disclosure: that 44.29% of affiliates earned nothing; that 93.458% never reached Leader rank; and that the average annual earnings of that sub-Leader group was $86.82, with a median of $3.00 - which is why no cohort here shows a majority in cumulative profit at any horizon. Anchored also to the published cost side: $0 entry with no kit and no mandatory tool fee, the $100-a-month subscription that unlocks up to $200 a month in product credit, published product prices, the ClearPath Circle Sales and team commission rates, and the Rising Affiliate gate on counting personal orders. MODELED by us: the entire expense side beyond the subscription, because the disclosure lists expense categories - events, insurance, product for personal use or promotion, tools, marketing materials, meals, entertainment - without a dollar figure; the share of each cohort in cumulative profit; and the cohort definitions. Note one structural quirk that shapes the table: because entry is genuinely free and there is no contractual monthly quota, the free-tier cohort is the only one on this site that sits close to break-even at the median - it is very hard to lose money if you never turn the subscription on. That is a real credit to the design. It is also why the subscription decision, and not the enrollment decision, is the one that matters.
Where you are actually allowed to promote this
Platform policy reads, not verifications. Check every one before you spend a dollar - enforcement changes faster than the written policy does.
Red flags and green flags
Red flags
141Affiliates below Leader rank earned $86.82 on average for the year, and $3 at the median
244.29% of affiliates earned nothing at all in 2025
3Only 6.54% reached Leader rank in 2025
4Direct Affiliate orders satisfy the customer-volume gates
5Part of compensation is paid in product credit, not cash
6Two founders left their previous employer under termination and litigation
7That former employer then collapsed without notice, and its field became this one
8The executive chairman previously ran a company that settled $47m over pyramid allegations
9Prices rose 8% to 20% across the range within eighteen months of launch
10The compensation plan has been revised repeatedly and then replaced
11Seven earnings claims removed after a self-regulatory challenge
12No peer-reviewed evidence on the finished products
13Termination forfeits the downline, and competing work can cost a top earner their pay
14Public records on the entity are thin and internally inconsistent
Green flags
91No unapproved-drug exposure - and this is the headline finding
2Entry is genuinely free, with no kit and no mandatory tool fee
3A near-total ban on paid advertising
4The income-claims rule is above sector standard on paper
5A 90% buyback within twelve months, plus a three-day cooling-off period
6No binary and no matching bonus
7Real branded ingredients with published clinical work behind them
8The self-regulatory case was resolved by full compliance
9No regulator action of any kind
We would like to be wrong about this
Upward
- Publishing the share of product volume purchased by non-affiliate customers, and closing the gap so that Direct Affiliate orders no longer count toward Circle Sales qualification (the current plan caps them at 500 of volume per Direct Affiliate a month but still counts them).
- A stable compensation plan held unchanged for two consecutive years, with a full rank-by-rank income table including expense data, and compensation paid in cash rather than product credit.
- Peer-reviewed clinical work on the finished products rather than an internal study, plus full disclosure of active amounts in place of proprietary blends across the whole range.
Downward
- Any injectable, sublingual or nasal SKU, or any FDA 503A Category 2 compound entering a formula - either would move this file to F immediately, regardless of anything else.
- An FDA warning letter, import alert or FTC action, or a second self-regulatory case on the same earnings-claim categories.
- A further compensation-plan rewrite that cuts payouts to existing affiliates, or a first earnings disclosure under ClearPath showing the bottom group earning less than 2025’s $86.82 average and $3.00 median.
Grade is D. The peptide scare is not the story - the story is $1,200 a year against a published average of $86.82, and a median of $3.
Most people arrive at a page about this company expecting an unapproved-drug problem, and the honest finding is that there is not one. Every product is oral, and every peptide in it is a plant or yeast hydrolysate, including a patented branded fava-bean ingredient with published clinical work behind it. Nothing on FDA’s Category 2 bulk-substances list appears in any formula. There is no injectable, no research chemical, no scheduled compound, and no FDA letter in the file. Add a genuinely free entry with no kit, a 90% twelve-month buyback, a three-day cooling-off period, a plan with no binary legs, and a ban on paid advertising apart from generic opportunity ads, and the structural design of this business is better than most of what gets graded here.
The problem is what the company’s own disclosure says happens to people. Some 93.458% of affiliates never reach Leader rank, and the average annual earnings of that group - nine in ten of everybody - is $86.82, with a median of $3.00. Just over 44% earned nothing at all. Against that sits the $100-a-month subscription that unlocks the product credits the plan is designed around: $1,200 a year, paying out on average roughly one dollar for every fourteen spent, with a chunk of what does come back arriving as store credit rather than cash. And the retail safeguard that should limit this has a hole in it, because orders from enrolled Direct Affiliates count toward Circle Sales alongside customer orders, up to 500 of volume per Direct Affiliate a month.
The remaining weight in the file is the founding team, and it has to be stated carefully because nothing has been proven against anyone. Two of the operating founders were terminated by their previous employer in October 2023 amid litigation in both directions over walking a salesforce out of one company and into a new one; no disposition of either action could be located. That former employer then collapsed with no notice in April 2025, and much of its field is now here - meaning a large share of this company’s participants have already lived through one overnight closure. The executive chairman previously led a company that settled a $47 million securities class action over pyramid allegations abroad and paid $765,688 to the SEC on books-and-records charges, neither admitted nor denied. That is a team that knows exactly how to build a nine-figure business in eighteen months. Whether it is a team that builds one that lasts is the open question, and a plan that reached its fourth revision by March 2025 and was replaced by ClearPath in June 2026 does not settle it.
Stay on the free tier and prove demand before you subscribe
Enrollment costs nothing and there is no monthly quota to hold an account. The $100 subscription is a separate, voluntary decision that unlocks credit rather than cash. Sell to actual customers first; if they reorder without you nudging them, the subscription question answers itself. If they do not, you have learned it for $0.
Ask what share of volume comes from non-affiliate customers
The Circle Sales volume gates are satisfiable with orders from enrolled Direct Affiliates, which makes the published figure much less informative than it looks. The number that actually matters - what proportion of product moves to people who are not in the plan - is not published, and asking for it is a fair question with a revealing answer either way.
If you want the ingredient, buy the ingredient
The patented fava-bean hydrolysate is a real, branded, clinically studied material and it is sold by other brands at roughly a third of the price. Buying it directly costs nothing in credits, nothing in subscription and nothing in downline politics - and you can read the full supplement facts instead of a proprietary blend.
Sell education, not enrollment, into the peptide category
Public confusion between oral peptide hydrolysates and injectable research chemicals is enormous, and it is where most of the harm in this space actually happens. Clear, sourced, claim-safe content on what is and is not regulated - and what FDA has actually said - is a merchant business with real demand, and it does not require a subscription or a downline.
Nine dimensions, weighted
Dimension profile
Further from center is better. Hover any point.
Hard caps that bind here
The lowest binding cap wins, regardless of the weighted arithmetic.
What we read
Every source below links to the document itself. Tier 1 is a primary record - the company’s own plan, policy or disclosure, a court filing, a regulator’s decision or an SEC filing. Tier 2 is a self-regulatory or secondary regulator record, tier 3 reporting or academic work, tier 4 an open-market price comparison. Where a document can be moved or withdrawn, an archived copy is linked beside it. If a link is dead when you try it, that is a correction we want.
- MAKE Wellness 2025 Earning Disclosure Statement - "2025 Typical Gross Earnings of MAKE Wellness Affiliates" (PDF; 44.29% of affiliates had no earnings, 93.458% below Leader at $86.82 average, expense categories not deducted)
MAKE Wellness Earnings Disclosure Statement, 2025 - 44.29% of affiliates earned $0; 93.458% never reached Leader rank; median annual earnings below Leader of $86.82; expense categories listed as not deducted
- MAKE Wellness Policies and Procedures for Affiliates (PDF) - defines the Company as "Upper Level Health, LLC, a Utah limited liability company operating as the d/b/a Make Wellness"; income-claim conditions, health-claim prohibition, buyback and cooling-off terms
MAKE Wellness Policies & Procedures, 1 September 2024 edition - total paid-advertising ban, marketplace prohibition, income-claim conditions, health-claim prohibition, broad non-compete, 90% twelve-month buyback, three-day cooling-off, AAA arbitration in Salt Lake County
- MAKE Wellness Compensation / Commissions overview (makewellness.com/content/docs/compensations.pdf) - Premier Affiliate qualification, Circle Sales Bonus $500 guarantee, $75 product credit, Direct Premier Guarantee
MAKE Wellness Compensation Overview Rev 4, 17 March 2025, superseded by the ClearPath Compensation Document (6/2026 V5) - Circle Sales up to 40% with $100, $200 and $500 guaranteed minimums, a six-tier Affiliate Development Bonus, the Total Team Bonus, $100 monthly subscription unlocking up to $200 in product credit; the $1,500 customer-volume rule was in Rev 1 (12 October 2024), not this edition
- MAKE Wellness "ClearPath" Compensation Overview, document version 6/2026 V5 (PDF) - leadership title ladder, Pay Volume thresholds, Pay Volume commission percentages 10% down to 1%, Team Bonus table and minimum-earnings guarantees
- MAKE Wellness official storefront home page - retail pricing for CALM $59.99, HYDRATED $54.99, FOCUSED $69.99, ENERGIZED $89.99, LEAN $99.99 and FIT $129.99
MAKE Wellness product pages and shop listings, 2026 - CALM $59.99, HYDRATED $54.99, FOCUSED $69.99, ENERGIZED $89.99, LEAN $99.99, FIT $129.99; November 2024 comparison prices from contemporaneous review coverage
Not established by this document: The November 2024 comparison prices cited from contemporaneous review coverage are not separately linked; the live storefront pages above carry the 2026 prices only.
- MAKE Wellness Peak Performance Collection product listing (MAKEshop item 63) - $504.94 one-time, $454.45 subscribe-and-save, with the six constituent product prices
- FDA, "Certain Bulk Drug Substances for Use in Compounding That May Present Significant Safety Risks" - the 503A/503B Category 2 list, including the 29 September 2023 entries for GHRP-2, GHRP-6, ipamorelin acetate and kisspeptin-10 with the agency's stated safety rationale
FDA 503A bulk drug substances lists - Category 2 additions of 29 September 2023 (GHRP-2, GHRP-6, ipamorelin, kisspeptin-10) and the nominated-then-withdrawn status of BPC-157, TB-500, GHK-Cu, KPV and epitalon; none appear in any MAKE formulation
- FDA, "Interim Policy on Compounding Using Bulk Drug Substances Under Section 503A of the Federal Food, Drug, and Cosmetic Act" - Guidance for Industry defining Categories 1, 2 and 3 of the interim 503A bulks list (PDF)
- Reed Smith LLP, "FDA removes certain peptide bulk drug substances from Category 2 of the interim 503A bulks list" - the 20 September 2024 removal of AOD-9604, CJC-1295, ipamorelin acetate, thymosin alpha-1 and Selank following nominator withdrawal, and the October/December 2024 PCAC referrals
- DSSRC Case #204-2025: Administrative Closure - MAKE Wellness, closed March 2025 (seven challenged earnings claims including "Uncapped Earnings … up to 40%!", all removed)
BBB National Programs, DSSRC Case #204-2025, closed 20 March 2025 - seven challenged earnings claims including "Uncapped Earnings…up to 40%!", all removed
- DSSRC Case #204-2025 decision, full text (PDF copy published by TINA.org)
- Justin K. Prince v. Modere, Maple Mountain Enterprises, Z Capital et al. - complaint filed in the Fourth Judicial District Court, Utah County, Utah, dated 17 October 2023 (full text published by Business For Home)
Utah Fourth District Court filings reported October 2023 concerning the founders and their former employer; contemporaneous trade reporting on that employer’s closure on 12 April 2025 and subsequent sale
- BehindMLM, "Top earner Justin Prince sues Modere after termination" - reporting the Fourth District Court of Utah filing
- BehindMLM, "Justin Prince sued for 'sabotaging and crippling' Modere" - Modere's counter-complaint in the Fourth District Court of Utah
- Direct Selling News, "Modere Announces Closure After 23 Years," 11 April 2025
- Nutraceuticals World, "Shaklee Acquires Rights to Modere Products after MLM Shuts Down" - the subsequent sale of substantially all of Modere's business
- In the Matter of Nu Skin Enterprises, Inc., SEC Administrative Proceeding File No. 3-17556, Exchange Act Release No. 78884 - Order Instituting Cease-and-Desist Proceedings, 20 September 2016 (disgorgement $431,088, prejudgment interest $34,600, penalty $300,000)
SEC administrative proceeding 3-17556, 20 September 2016 ($765,688 total, neither admitted nor denied) and the $47m securities class settlement over China pyramid allegations, both relating to the executive chairman’s former employer
- SEC press summary, "SEC Charges Nu Skin Enterprises, Inc. with FCPA Violations," Administrative Proceeding File No. 3-17556, 20 September 2016 ($765,688 total)
- Nu Skin Enterprises, Inc. Form 8-K, 22 February 2016 - $47 million settlement term sheet in In re Nu Skin Enterprises, Inc. Sec. Litig., No. 2:14-cv-00033-JNP-BCW (D. Utah), the China pyramid-allegation securities class action
- Nu Skin Enterprises, Inc. Form 8-K, 20 September 2016 - disclosure of the SEC resolution and the $765,688 payment, neither admitted nor denied
- DSN Global 100 for 2026 (based on 2025 revenue) - MAKE Wellness at rank 41 with $102M, alongside Bravenly Global at $102M; published list
Direct Selling News Global 100, 2026 edition - $102m 2025 revenue, rank #41; BBB business profile for the trading entity
- Direct Selling News, "Bravo Growth Award | MAKE Wellness" - DSN's own award citation reporting $104M revenue in the first full year
- Better Business Bureau business profile, Make Wellness, 169 W 2710 South Cir Ste 202A, St George, Utah - file opened 30 December 2024, business started 23 January 2024, type of entity Limited Liability Company, alternate name Upper Level Health, LLC
What we could not get
- The Utah filing number for Upper Level Health, LLC, and the LLC-versus-S-corporation discrepancy between the entity name and the BBB profile
- The $20 million 2024 revenue figure underpinning the growth story - it is a third-party estimate, and the $102 million 2025 figure is unaudited
- The outcome of the October 2023 litigation between the founders and their former employer, in either direction
- The share of revenue paid out under ClearPath across Circle Sales, Pay Volume and Legacy commissions, guaranteed minimums, product credit and one-time bonuses - the plan publishes its rates and thresholds but no payout ratio and no company-wide cap
- The split of product volume between enrolled affiliates and non-affiliate customers - the decisive Koscot number, and it is not published
- The proportion of total compensation paid as product credit rather than cash
- The actual milligram content of the branded hydrolysate in each SKU, and the supplement facts and price for the RESTORED product
- The identity of the seller behind the MAKE-branded marketplace listings, event ticket costs, and whether the company holds any direct-selling trade-association membership
Not advice
This is independent analysis for decision-making, not legal, financial or investment advice. Allegations reported by third parties should be verified against primary court and regulatory records before any decision.
Researched by Claude. Reviewed by an editor.
Every report is researched and written by Claude, Anthropic’s AI assistant, from the company’s own plan documents, policies, terms and regulatory file - then reviewed before publication by Rob Fore, who checks the sources and the stage-label on every allegation.
- Nine weighted dimensions, published with their weights
- The editor checks the evidence and cannot change the number - the build rejects any page whose grade does not reconcile to its own arithmetic
- Every affiliate position we hold is disclosed on the report it touches
- No company has paid for a grade, and no report carries an affiliate link
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MAKE Wellness - frequently asked
QAre MAKE Wellness peptides legal, or are they unapproved drugs?
QHow much do MAKE Wellness affiliates actually earn?
QIs MAKE Wellness free to join?
QIs MAKE Wellness a pyramid scheme?
QWho is behind MAKE Wellness?
Author, editor and publisher
This report was researched and written by Claude, Anthropic’s AI assistant, working from primary documents - MAKE Wellness’s own compensation plan, its policies and procedures, its terms of service, its income disclosure statement where one exists, and its regulatory and self-regulatory file. It was scored against nine weighted dimensions that are published in full, with their weights, on the methodology page.
Before publication it was reviewed by Rob Fore, who checks every source link, every figure against the document it came from, and every allegation against its stage-label - an investigation is not a finding, a warning letter is not an enforcement action, and a filed claim is not a verdict.
The editor does not set the grade. The published score is the weighted composite of the nine dimension scores, and the build refuses to emit a page where the two disagree by more than 0.06. A grade moves when the evidence moves it and not otherwise.
Rob Fore has marketed online since 1996, wrote Online MLM Marketing (2014), and is CEO of Listech Inc, the Nevada corporation that publishes this site. He holds affiliate positions in companies graded here - including LiveGood, which this site grades D, SendOutCards, which it grades C−, and the Home Business Academy, which it grades B−. Those positions are disclosed on the reports they touch, and changed nothing on this page.
About the author and our conflicts · Contact the editor · Corrections: corrections@opportunitygrade.com
Tell me if this grade changes
MAKE Wellness is graded D as of July 28, 2026. Grades move when the evidence moves - a new income disclosure, a regulatory action, a rewritten compensation plan. Leave your address and you will get one email if this one does.
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Corrections
Every factual claim on this page is sourced, and the ones we could not stand up are named in the unable to verify list above. If something here is wrong, we want to know, and we would rather hear it from MAKE Wellness than from a reader.
Write to corrections@opportunitygrade.com. Point at the specific sentence and send the document that contradicts it - a plan document, a filing, an income disclosure, a policy page. We will check it against the primary source, correct the page if it is wrong, and keep a dated record of the change. A grade moves if the evidence moves it.
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