New U Life Corporation
A gel marketed as growth hormone whose own FDA-filed label declares a 30X dilution - and an FDA laboratory analysis in January 2019 found no meaningful growth hormone in it. No regulator has acted in the six-plus years since, and that absence is part of the file too.
The company’s own 2023 disclosure puts the average annual income across active distributors at $49.45, against roughly $1,560 a year of autoship required merely to stay commission-eligible - and the product at the center of it is labeled at a dilution that, on ordinary chemistry, retains no molecule of the substance it is named for.
Can you actually make money with New U Life?
No, and the product is the reason before the economics are. The label on the flagship gel declares "Somatropin 30X" - thirty successive one-in-ten dilutions, a factor of ten to the thirtieth, roughly a million-fold past the point at which a solution is statistically expected to hold one molecule of the original substance. An FDA Forensic Chemistry Center report on a January 2019 sample recorded no evidence for the presence of hGH above approximately 7 micrograms per gram. That is a laboratory finding inside an FDA document, not a warning letter, not a recall and not an adjudication. It is also exactly what the label says.
The economics come from the same paper trail. The company's own 2023 disclosure puts the average annual income across active distributors at $49.45, with no median published, and 99.44% of distributors sitting at the Associate rank averaging $1.05. Staying commission-eligible takes 140 PV inside a rolling five-week period, which in practice is autoshipping a bottle every five weeks: roughly $130 to $150 a month, about $1,560 a year, indefinitely. The required spend is around thirty-one times the average receipt, and that average is computed only across people still maintaining the volume.
Roughly half the payout is gated on sponsoring. Binary team commissions require 140 PV personally, or 280 at Coach and above, plus at least two personally sponsored active affiliates each generating 140 PV of their own. The unilevel matching bonus pays a percentage of downline binary commissions, so it sits behind the identical gate. A person who sells nothing but product to outside customers is structurally excluded from both streams at any volume. And the fast start pays the sponsor $20, $60 or $120 depending on which kit the recruit bought on the way in.
Two things cut the other way and belong on the page. The retail margins are real - $45 on a single non-autoship bottle, $25 on autoship, $520 on a forty-gel commercial order - so three outside sales a month covers the activity requirement for somebody who can genuinely find buyers. And no second monetisation layer is stacked on top: no mandatory training fees, no certification charges, no leadership-program costs and no ticketed event obligations could be located in any source reviewed. In this category that absence is worth more than it sounds.
entry kit, with higher tiers reported at $499–$559 and $899–$999; then 140 PV every five weeks - roughly $130–$150 a month - to stay commission-eligible
- Stop naming the product after a substance an FDA laboratory did not find in it. The 30X notation on the label and the January 2019 sample report say the same thing; the marketing says something else.
- Publish a median beside the average. In a distribution where 99.44% of distributors average $1.05 and the top rank averages $295,790.25, a mean of $49.45 describes almost nobody in the field.
- Ungate the binary from personally sponsoring two people. As drafted, a distributor who sells only to outside customers is shut out of roughly half the plan no matter how much they move.
- Publish the exit and refund terms. The buyback percentage, the return window and the treatment of unopened inventory could not be verified anywhere, and the activity requirement generates a bottle every five weeks whether or not it sells.
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 - and the list of what has NOT been found is long enough that it has to come first. No court has found anything against New U Life. No FTC action, no FTC complaint, no consent order, no civil penalty. No FDA warning letter to the company could be located anywhere in the FDA warning-letter database, including its 2019 health-fraud compilation. No product recall, no seizure, no injunction. No pyramid-scheme finding by any government body. No class action and no state attorney general action was identified in any source reviewed. No criminal proceeding and no securities action against any principal. What does exist: an FDA Forensic Chemistry Center laboratory summary report, Sample No. 1026141, on a product tested in January 2019, finding no evidence of human growth hormone above approximately 7 micrograms per gram - a laboratory result recorded in an FDA document, not a warning letter, never sent to the company, and surfaced instead by a private watchdog; a March 2020 self-regulatory decision, DSSRC Case #16-2020, referring the company’s health and earnings claims to both the FTC and the FDA, which produced no visible federal enforcement in more than six years; an FTC closing letter of 5 August 2019 to the founder concerning a prior company, closing an inquiry with no enforcement action; unresolved internal-control litigation; and two defamation suits the company itself filed against critics, outcomes unverified. Every one of those is a stage, and none of them is an adjudication.
Confidence: Medium-High
Primary sources fetched directly where possible. Everything we could not verify is listed at the bottom of this page by name.
Follow the money
A California direct-selling company registered in April 2017 and launched into the field in 2017–2018, selling a topical gel called SomaDerm - marketed as delivering growth hormone transdermally without a prescription - plus an adjacent supplement line, through independent distributors on a binary team-commission core with unilevel matching bonuses layered over it.
Several things about it are better than the surrounding noise suggests and they belong first. It publishes a dated, named income disclosure at a stable public address, with a rank-by-rank table, which a large share of this category still does not. It is self-funded with no reported outside institutional investors, so there is no fund with an exit clock behind the growth targets. There is no second pay-to-play layer - no mandatory training fees, no certification charges, no event or ticket requirements were located anywhere. The binary carries a real anti-abuse cap at 417 cycles a week. The BBB file shows an A- grade with low absolute complaint volume for a company of this claimed scale. And the corporate language is, at the top of the house, comparatively careful: the product label carries the mandated homeopathic disclaimer verbatim and the company’s own FAQ states plainly that the product is not FDA approved.
Then the product. SomaDerm sells at a reported $169–$170 for a 96-gram bottle. Its own FDA-filed label lists the active ingredient as "Somatropin 30X" - a one-in-ten dilution repeated thirty times, a factor of 10^30, roughly a million-fold beyond Avogadro’s number, which is the point past which a solution is not statistically expected to retain a single molecule of what was diluted. An FDA Forensic Chemistry Center laboratory summary report, Sample No. 1026141, on a product tested in January 2019, recorded "no evidence for the presence of hGH at a level greater than approximately 7 micrograms per gram." That is a laboratory finding in an FDA document - obtained and published by a private watchdog, never issued to the company as a warning letter, never followed by a recall, a seizure, an injunction or any enforcement action in the years since. The absence is as material as the finding and this report states both.
And "FDA registered" is not "FDA approved," and neither is a national drug code listing. The product is listed in the FDA’s NDC directory under 61877-0007 in the marketing category "UNAPPROVED HOMEOPATHIC." An NDC listing is a self-reporting process by which a firm tells the FDA it makes or distributes something and self-assigns a code. There is no review, no testing and no authorization of any claim in it. The product’s own label says so: "This homeopathic product has not been evaluated by the Food and Drug Administration for safety or efficacy. FDA is not aware of scientific evidence to support homeopathy as effective." A private watchdog has documented dozens of instances of distributors using "FDA registered" and, in places, the flatly false "FDA approved."
The plan behind it gates roughly half its payout streams on headcount. Binary commissions - $40 a matched cycle at Promoter and Coordinator, $60 at Coach and above, on 600/400 PV matched cycles - require 140 PV personally and at least two personally sponsored active affiliates each doing 140 PV of their own. The unilevel matching bonus pays a share of downline binary commissions and so is gated behind the same condition. A distributor who only sells to outside customers is left with $45 on a single gel order and $25 on an autoship order. Staying commission-eligible at all costs 140 PV every five weeks - about $130 to $150 a month. The company’s own 2023 disclosure puts the average annual income across active distributors at $49.45, with 99.44% of them at the Associate rank averaging $1.05, and publishes no median.
Where distributors sat in the company’s own 2023 disclosure
New U Life’s published earnings summary. Percentages of distributors by rank; income figures are averages, not medians - no median is published. Business expenses are expressly not deducted, and the denominator counts only distributors maintaining 140 PV in a rolling five-week period, so the figure across everyone who ever paid a kit fee is lower still.
| Product | Price | Pays |
|---|---|---|
| Basic entry kit ("New U Pack") One bottle of SomaDerm, a one-year affiliate membership and a replicated website. The $199 figure is corroborated across all three independent reviews consulted. The renewal position after the first year is not clearly disclosed anywhere. |
$199 one-time |
$20 to the sponsor |
| Pro Pack Four to six bottles plus membership and website. Sources conflict on the exact price and this report does not resolve the conflict. At roughly $170 a bottle retail-equivalent, the pack is priced near the notional value of the product in it, which is what makes the "kit discount" framing work. |
$499 or $559 one-time |
$60 to the sponsor |
| Executive Pack Eight bottles plus membership and website. Sources conflict on the exact figure. Note that the sponsor bonus scales with what the recruit spent on entry - $20, $60, $120 - which is a statement about what the plan rewards. |
$899 or $999 one-time |
$120 to the sponsor |
| SomaDerm gel - single retail bottle The flagship. A real per-unit margin on a real repeat-purchase consumable, and the only income stream available to a distributor who does not recruit. The retail price comes from reviews dated 2019–2023 and could not be reconfirmed at the current storefront. |
$169–$170 (96 g) per unit |
$45 |
| SomaDerm on autoship The discounted subscription price, cited by one 2025-era review. The commission on an autoship order is $25 rather than $45 - the recurring order pays the seller less per unit than the one-off. |
~$149.99/month recurring |
$25 |
| 140 PV activity requirement Required within a rolling five-week window to remain eligible for any commission at all, retail or team; 280 PV at Coach rank and above for certain qualifications. Roughly $1,560–$1,800 a year, realistically satisfied by autoshipping one bottle of the flagship every five weeks. |
~$130–$150/mo recurring |
— |
| Commercial customer bulk order The largest single retail-side commission in the plan. It is a genuine wholesale mechanic and it is listed here because it is the one route by which a pure seller could earn meaningfully without recruiting - if a buyer for forty bottles exists. |
40 gels per order |
$520 |
| Car bonus A cash allowance of $700 a month at Coach rank and $1,500 at Ambassador and above, tied to maintained rank. Not a vehicle and not equity - a rank-maintenance payment, and the ranks that earn it are the ranks carrying the highest personal volume obligations. |
— monthly |
$700 or $1,500 |
Who runs it, and what they ran before
Immigrated to the United States as a teenager, took over a family natural-foods and supplement shop in Pleasant Hill while completing a business degree, and describes himself as a Certified Homeopath and Certified Herbalist - self-reported credentials in a company-friendly trade profile, with no issuing body or accreditation independently verified. He states SomaDerm was developed for athletic recovery and sold at ordinary retail for over sixteen years before the direct-selling launch; if accurate that is a materially better origin story than a product invented to give a compensation plan something to sell, but no pre-2017 retail records could be located to corroborate it. No criminal proceeding, no securities action, no fraud judgment and no regulatory bar against him could be located in any source reviewed.
Before New U Life, the founder owned this company, which marketed Testall Gel - a topical advertised as "the only FDA-registered transdermal testosterone product available without a prescription" and claimed to strengthen bone density, reduce the risk of osteoporosis, balance blood sugar, reduce blood pressure and prevent depression. On 5 August 2019 the Associate Director of the FTC’s Division of Advertising Practices sent a closing letter to his counsel stating that staff had investigated whether the claims violated Sections 5 and 12 of the FTC Act and had decided not to pursue enforcement, citing modest sales volume and the fact that the product had already been discontinued. Stage label, precisely: that is an inquiry closed with no action. It is not a finding of violation and the letter expressly says it is not a determination that no violation occurred. It is neither a conviction nor an exoneration. What makes it material is not the letter but the pattern it sits inside - an unapproved homeopathic hormone gel, "FDA-registered" framing, sweeping health claims - recurring one product cycle later under a new corporate name.
A thirteen-count complaint filed by George Najjar against the founder and others, alleging wrongful removal as a founder figure and seeking reinstatement, with a preliminary injunction reported as barring asset transfers, dissolution, or the use of alternate entities to sell growth-hormone or testosterone products pending resolution. The docket reference available dates to August 2019 and the current status and outcome could not be located. Stage label: filed claims and a reported interim order, nothing proven, nothing resolved on the public record available. It is recorded because an unresolved dispute over who controls a company is a fact a prospective participant should know, not because any allegation in it has been established.
New U Life filed against two former distributors within a week of each other: one over comments posted on an MLM-watchdog site, one over private Facebook messages describing company leadership as "crooks and manipulators." Each sought damages in excess of $100,000. The outcomes of both could not be verified in any source reviewed. Stage label: these are civil claims filed by the company, not government enforcement and not adjudicated findings against anyone. They are recorded here for one reason only - how an operator responds to criticism from its own field is directly relevant to whether a prospective distributor can expect problems to be reported or suppressed, and that is true regardless of who is right on the merits of either suit.
Registered address
Pleasant Hill, California, USA
Self-funded, privately held, with no reported outside institutional investment - a genuine structural credit, because there is no fund with an exit clock pushing recruitment metrics. Operations are described in a trade-press profile as spanning Pleasant Hill, a larger office in Lehi, Utah, and an office in Taipei. There are no audited accounts, so every revenue figure in this report is a third-party estimate published by an industry aggregator rather than a company statement or a filed financial: roughly $272 million in 2020 falling to roughly $128 million in 2025. Treat those as unaudited estimates, and treat the direction of travel - a decline of roughly half across five years - as the part that matters, because it tracks the company’s own disclosed average income falling across three disclosure cycles. A distributor headcount of about 395,000 comes from a 2020 profile and no more recent official figure could be located.
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
New U Life Corporation, California entity C4017199, registered April 2017, Pleasant Hill. Privately held and self-funded with no reported outside investors and no audited accounts. Note that the entity named as labeler on the product’s own drug filing is a different name - "Natural Life Foods Corporation dba XYGENYX and Apotheca Company."
|
| Is the product FDA approved? |
RED
No. It is listed in the FDA drug-code directory under the category "UNAPPROVED HOMEOPATHIC," which is a self-reporting listing process, not a review, not clearance and not approval. The product’s own label states it has not been evaluated by the FDA for safety or efficacy.
|
| What did the FDA laboratory actually find? |
RED
Forensic Chemistry Center summary report, Sample No. 1026141, product tested January 2019: no evidence of human growth hormone above approximately 7 micrograms per gram. That is a laboratory finding in an FDA document, published by a private watchdog - not a warning letter, not a recall, not a court finding. No enforcement, seizure or injunction followed.
|
| What does it really cost? |
CONCERN
$199 for the entry kit, with higher tiers reported at $499–$559 and $899–$999, then 140 PV every five weeks - roughly $130 to $150 a month, or $1,560 to $1,800 a year - to stay eligible for any commission. A renewal fee after the first year is implied by the "one-year membership" wording but is not clearly disclosed anywhere.
|
| Published income disclosure? |
CONCERN
Yes, dated and public, which is a genuine credit. It shows an average annual income across active distributors of $49.45 for 2023, with 99.44% at the Associate rank averaging $1.05. No median is published, and the average has fallen from $117.15 in 2021.
|
| Has any regulator acted against it? |
WATCH
No. No FTC action, no consent order, no FDA warning letter, no recall, no seizure, no injunction, no pyramid finding, no class action and no state attorney general action was identified. A self-regulatory body referred the company to both the FTC and the FDA in March 2020; more than six years on, nothing has resulted.
|
| Can you earn without recruiting? |
CONCERN
Partly. Retail commissions of $45 a bottle, $25 on autoship and $520 on a forty-gel commercial order are real and require no downline. But binary team commissions and the unilevel matching bonus - roughly half the plan - require two personally sponsored active affiliates, and no volume of retail sales substitutes for them.
|
| Merchant play or miner play? |
CONCERN
Miner, with a working merchant half attached. The retail margins are genuine and a capable seller breaks even in two or three months. The plan nonetheless gates its team-commission machinery on headcount and its qualification mechanic on recurring self-purchase.
|
What has to be true for you to get paid
| To cover | You need |
|---|---|
| Buy in and hold the position for one year | $199 + ~$1,560 entry kit plus 140 PV every five weeks at roughly $130 a month |
| Cover the ongoing autoship from retail margin alone | ~3 outside sales a month three non-autoship bottles at $45 = $135 against ~$130 of qualifying spend |
| Recover the $199 kit on top of that | ~4-5 further sales pushing full break-even to month two or three for a genuinely capable seller |
| Beat the mandatory autoship from the average income | ~31x the average outcome $49.45 average annual income against ~$1,560 of annual qualifying spend |
Read this twice
The arithmetic here is short and it comes from two published sources - the company’s own 2023 earnings summary and a compensation-plan teardown by the most granular independent reviewer of MLM plan mechanics. The activity requirement is 140 PV in a rolling five-week window, which realistically means autoshipping one bottle of the flagship gel every five weeks: about $130 to $150 a month, $1,560 to $1,800 a year, indefinitely, simply to remain eligible to be paid anything at all. The company’s disclosed average annual income across active distributors is $49.45. So the mandatory spend is around thirty-one times the average receipt, and the average is a mean in a violently right-skewed distribution with no median published - 99.44% of distributors sit at Associate rank averaging $1.05 for the year, while the Diamond Ambassador rank averages $295,790.25 and holds under 0.1%. Two honest caveats belong here and both cut for the company. The 140 PV can in principle be met by genuine outside customer orders rather than self-purchase, and a distributor with a real customer base is not spending that money at all - $45 a bottle on a non-autoship retail order is a workable margin, and the forty-gel commercial order pays $520, which is a serious commission by any standard. And the retail-only path really does break even inside two or three months for someone who can find three to five outside buyers a month, which is a nontrivial but not impossible bar. The bind is the one the plan builds in deliberately: that same retail-only distributor is excluded from binary and matching commissions entirely, because those require two personally sponsored active affiliates. The break-even that matters is therefore not whether the product can be sold - it can - but whether $170-a-bottle repeat customers who are not themselves distributors exist in the numbers required, which is precisely the question the independent reviewer says the plan cannot answer, and which no published retail-versus-internal volume figure exists to settle.
Run your own numbers
Drag the sliders. Nothing here is stored or sent.
A retained customer on the recurring gel order pays the referring affiliate $25; a one-off order without autoship pays $45, and the plan is deliberately structured so the recurring number is the lower one. Cost is the requirement that decides this business: 140 PV every five weeks to stay commission-eligible, which in practice is close to a bottle of the roughly $170 flagship gel on repeat, or about $147 a month before the entry kit. That figure is payable whether or not anyone else ever orders. The binary cycles and the matching bonus are excluded because roughly half the payout is gated behind personally sponsoring at least two active participants, which is a headcount condition rather than a sales one. For calibration, the company’s own most recent disclosure puts average annual income across active distributors below $50 - an average, with no median published, which flatters it - while the autoship alone runs past $1,700 a year. The slider will show that gap long before it shows a profit. Your own subscription cost of $147/mo is included.
What it costs to replace this yourself
What the same money buys at ordinary retail. Two separate comparisons are drawn and they must not be conflated. The first is against ordinary consumer wellness products at pharmacy and supermarket prices - this is the graded comparison, because it asks what the article in the bottle is worth as the article it chemically is. The second, given at the end, is against genuine prescription growth-hormone therapy from a licensed clinician; that is a lawful medical treatment, it is not a comparator for grading purposes, and it is included only because it is the honest answer to what a prospective buyer is actually reaching for.
| What they sell you | What you'd use instead | Your cost |
|---|---|---|
| SomaDerm gel - $169–$170 for 96 g | Any mainstream pharmacy homeopathic preparation at 30X or higher - the same expected molecular content | ~$8-20 |
| The "anti-ageing topical" positioning | Drugstore vitamin-C or antioxidant botanical serum of the same class | ~$10-30 |
| Aloe vera, green tea leaf extract, licorice on the label | Aloe and green-tea botanical cream at an ordinary chemist | ~$10-25 |
| Wild yam and chaste tree on the label | Wild-yam or phytoestrogen topical cream at retail | ~$12-28 |
| Claimed benefits - sleep, mood, energy | Mainstream magnesium or melatonin sleep supplement, monthly | ~$8-20/mo |
| Claimed benefits - joint mobility | Standard glucosamine and chondroitin joint supplement, monthly | ~$12-25/mo |
| Claimed benefits - skin, hair, nails | Ordinary multivitamin with collagen, monthly | ~$15-30/mo |
| 140 PV every five weeks to stay commission-eligible - ~$1,560-1,800/yr | No activity requirement, no rank, no qualification | $0 |
| Total as sold ~$1,760-2,800 in year one, kit included |
Total, built yourself ~$60-160 of comparable topicals and supplements, bought once |
Price-to-value
The multiple on the bottle alone is roughly six to twenty times, depending on which retail article you treat as the honest equivalent - and the honest equivalent is decided by the label, not by the marketing. A 30X preparation is, on ordinary chemistry, an inert dilution in a botanical gel base, and inert dilutions in botanical gel bases sell in ordinary chemists for eight to twenty dollars. The structural gap is larger than the per-bottle gap: the kit, plus the 140 PV every five weeks, turns a preference for a topical gel into roughly $1,760 to $2,800 of committed first-year spend. Separately and on a different footing entirely: genuine prescription growth-hormone therapy, from a licensed clinician after bloodwork and a diagnosis of actual deficiency, is estimated at roughly $800 to $3,000 a month - around $1,200 typical - inclusive of consultation, laboratory work and injectable recombinant hormone. That is eight to twenty times more expensive than this gel, and it is a different thing. A buyer who wants growth-hormone replacement is not buying a cheaper version of it here.
Three operators, five horizons
Probability of cumulative net profit
Hover any point for median, top decile and bottom quartile.
The believer-consumer
joins for the personal-use discount, autoships indefinitely, refers a few friends
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 4% | −$540 |
| 6 mo | 4% | −$960 |
| 1 yr | 3% | −$1,720 |
| 3 yr | 3% | −$4,900 |
| 5 yr | 3% | −$8,000 |
The side-hustle retailer
3-5 bottles a month to genuine outside customers, no recruiting
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 22% | −$180 |
| 6 mo | 29% | −$130 |
| 1 yr | 33% | −$120 |
| 3 yr | 31% | −$700 |
| 5 yr | 29% | −$1,400 |
The builder chasing rank
recruits actively, aims at Coordinator or Coach within 12-18 months
| Horizon | P(profit) | Median |
|---|---|---|
| 3 mo | 6% | −$900 |
| 6 mo | 8% | −$1,700 |
| 1 yr | 10% | −$2,900 |
| 3 yr | 12% | −$7,400 |
| 5 yr | 13% | −$11,000 |
Methodology note. These are modeled outcome ranges, not claims, not promises and not company figures. ANCHORED to published numbers: the company’s own 2023 earnings summary, which puts 99.44% of distributors at Associate rank with an average annual income of $1.05, Promoter at 0.3% averaging $502.08, Coach averaging $11,359.06, Ambassador $37,143.04 and Diamond Ambassador $295,790.25 with every rank above Promoter under 0.1% of the field; the disclosed all-distributor average of $49.45, falling from $117.15 in 2021; and the published cost side - the $199 entry kit, the 140 PV rolling five-week activity requirement at roughly $130 to $150 a month, the $45 and $25 per-bottle commissions, the $520 forty-gel commercial commission, and the $20, $60 and $120 fast-start bonuses. MODELED by us: the proportion of each cohort in cumulative profit, the cohort definitions themselves - the company does not segment its field this way - and the expense side beyond the published items, because the earnings summary expressly states that business expenses including autoship, marketing, samples and travel are not deducted from the figures it reports. Two calibration notes cut in the company’s favor and should be read alongside the tables. The activity requirement can be satisfied by genuine outside customer orders rather than self-purchase, so a distributor with a real customer base is not carrying that $1,560 at all - which is exactly why the retailer profile is the only one of the three with a meaningful share in profit at any horizon. And the top column in the builder row is real: the plan does produce substantial income for a very small number of people, and the disclosure says so itself. What the tables are built to show is the shape of the distribution, not the ceiling of it.
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
151An FDA laboratory found no meaningful growth hormone in the product
2The label’s own dilution notation says the same thing
3Listed with the FDA is not approved by the FDA, and it is not cleared either
4Distributors have been documented claiming the product is "FDA approved"
5A self-regulatory body referred the company to both the FTC and the FDA in March 2020
6No federal enforcement followed that referral in more than six years
7COVID-19 treatment and prevention claims by distributors
8Roughly half the plan’s payout streams are gated on personally sponsoring two people
9Staying eligible to earn anything costs roughly $1,560 to $1,800 a year
10The disclosure publishes an average and no median
11Average disclosed income has fallen across three cycles
12Estimated revenue has roughly halved since 2020
13The entity on the drug label is not the entity selling the opportunity
14The founder’s prior venture ran a closely similar claim pattern
15Unresolved internal-control litigation and defamation suits against critics
Green flags
101There is no securities exposure here at all
2It publishes an income disclosure at all, at a stable public address
3No pay-to-play beyond the kit and the activity requirement
4Self-funded, with no outside institutional investors
5The corporate label and FAQ language are comparatively disciplined
6Retail commissions are genuine and a retail-only seller can break even
7The binary carries a real anti-abuse cap
8A genuine repeat-purchase consumable, with low complaint volume for its scale
9No pyramid finding, no enforcement action, no court finding, anywhere
10A claimed pre-MLM retail history for the product
We would like to be wrong about this
Upward
- A completed, independently published third-party efficacy study for the product - the company has said one is in progress - together with a corporate decision to stop marketing a 30X preparation with hormone-delivery vocabulary, which is the single largest available upgrade because it is what the whole file turns on.
- An income disclosure that publishes a median beside the average, a zero-earner percentage, headcounts by rank and an expense-adjusted net figure; plus a published retail-versus-internal volume split, which would directly answer the one structural question no source can currently settle.
- Resolution of the internal-control litigation with clean governance established, an end to the practice of suing distributor critics, a clearly disclosed renewal fee and buyback policy, and a documented compliance audit showing "FDA approved" claims in the field have measurably stopped.
Downward
- Any actual FTC or FDA enforcement action - a complaint, a warning letter, a consent order, a seizure, an injunction or a recall - which would convert a six-year unresolved absence into an adverse finding and would make an F ceiling bind immediately.
- A confirmed action by an overseas medicines regulator in any of the markets the company has entered, or a confirmed class action or state attorney general action, none of which was identified as of this review.
- A further income disclosure showing the all-distributor average falling below $49.45, or confirmation that the post-first-year renewal fee is materially higher than the sources suggest, either of which worsens an already inverted break-even.
Grade is D-, score 3.14. No regulator has acted against this company in six years - and its own product label declares a dilution that, on ordinary chemistry, contains nothing of what the product is named for.
Say the good parts first and mean them. There is no securities exposure in this file at all: no investment contract, no promised return, no token, no equity, no securities regulator anywhere. The company is self-funded, so nobody behind it has an exit clock. It publishes an income disclosure at a stable public address with a rank table on it, which a great many companies in this category simply do not. There is no second pay-to-play layer - no training fees, no certification charges, no event or ticket requirements were located anywhere. The binary carries a genuine cap at 417 cycles a week. Retail commissions are real: $45 a bottle on a one-off order, $520 on a forty-gel commercial order, and a capable seller covers the activity requirement on three outside sales a month. And the corporate language is careful where it counts - the label carries the mandated disclaimer verbatim, and the company’s own FAQ says in terms that the product is not FDA approved.
Then the product, stated with precision and no embellishment. SomaDerm sells at a reported $169 to $170 for a 96-gram bottle and is marketed as delivering growth hormone through the skin. Its own FDA-filed label lists the active ingredient as "Somatropin 30X" - thirty successive one-in-ten dilutions, a factor of 10^30, roughly a million-fold beyond the point at which a solution is expected to retain any molecule of what was diluted. An FDA Forensic Chemistry Center laboratory summary report, Sample No. 1026141, on a product tested in January 2019, found "no evidence for the presence of hGH at a level greater than approximately 7 micrograms per gram." That is a laboratory finding in an FDA document, surfaced by a private watchdog - not a warning letter, not a recall, not a court finding, not an adjudication - and no seizure, injunction, recall or enforcement action followed it in the years since. The label also says, because it must: "This homeopathic product has not been evaluated by the Food and Drug Administration for safety or efficacy. FDA is not aware of scientific evidence to support homeopathy as effective." Being listed in the FDA drug-code directory is not approval and it is not clearance. It is a self-reporting exercise.
And the plan around it. Roughly half the payout streams - binary team commissions and the unilevel matching bonus that overrides them - require two personally sponsored active affiliates before a distributor can touch either. Remaining eligible to earn anything costs 140 PV every five weeks, about $1,560 to $1,800 a year. The company’s own 2023 disclosure puts the average annual income across active distributors at $49.45, with 99.44% at the Associate rank averaging $1.05, and no median is published in a distribution where the top rank averages $295,790.25. That average has fallen from $117.15 in 2021, while third-party unaudited estimates put revenue down from roughly $272 million in 2020 to roughly $128 million in 2025. In March 2020 a self-regulatory body referred the company’s health and earnings claims to both the FTC and the FDA after finding it had repeatedly failed to follow the body’s own recommendations; nothing came of it in more than six years. None of that is a court finding. All of it is the file.
Buy the product as a product, if you want it - and read the label first
You do not need a distributor position to buy a bottle, and the position costs $199 plus roughly $130 a month to keep alive. Before you buy either, read the two sentences the FDA requires on the label: that it has not been evaluated for safety or efficacy, and that the FDA is not aware of scientific evidence supporting homeopathy as effective. Then look at "Somatropin 30X" and understand what the notation means. If you still want the gel for its aloe, green tea and licorice, an ordinary chemist sells that category of thing for $10 to $30.
Do the $49.45-against-$1,560 sum before you enrol
Both numbers are available. One is the company’s own disclosed average annual income across active distributors; the other is what the 140 PV activity requirement costs over a year if outside customers do not cover it. If the mandatory spend is roughly thirty-one times the average receipt, the question is not whether anyone wins - some clearly do - but what specific, written-down reason you have to believe you are not the average. And remember the average is a mean with no median beside it.
If you go anywhere near this, go retail-only and price the gate honestly
The retail side is the honest half: $45 a bottle on a one-off order, $520 on a forty-gel commercial order, break-even inside two or three months for someone who can genuinely find three to five outside buyers a month. But understand the bind the plan builds in - with no recruits you are locked out of binary and matching commissions permanently, at any sales volume. Decide whether you are willing to be a retailer inside a plan that pays its retailers second, and get the renewal fee after year one, the buyback percentage and the return window in writing before you spend anything.
Sell into the anti-aging and hormone-health question without the plan
Search demand around growth hormone, aging, sleep, recovery and hormone testing is enormous and the honest information supply is thin. Explaining what a homeopathic X dilution actually is, what "FDA registered" does and does not mean, and what a licensed clinician charges for genuine prescription therapy after real bloodwork - roughly $800 to $3,000 a month - is content with real demand and no kit, no activity requirement, no rank and no obligation to be careful about what you say. It is also, on the evidence in this report, more useful to the reader than the product.
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.
- FDA Forensic Chemistry Center Case/Sample Summary Report, Sample No. 1026141 - SOMADERM Transdermal Homeopathic Gel, analyzed January 2019 (PDF, obtained and published by TINA.org)
FDA Forensic Chemistry Center summary report, Sample No. 1026141, product tested January 2019 - analysis for identification and quantification of human growth hormone and testosterone by LC-MS and GC-MS; finding of no evidence of hGH above approximately 7 micrograms per gram and no evidence of any drugs or poisons. Obtained and published by a private advertising watchdog; not an FDA warning letter and not issued to the company
- TINA.org, "What You Should Know about New U Life" - the article reporting the Forensic Chemistry Center finding of no hGH above ~7 µg/g
- DailyMed label: SOMADERM (glandula suprarenalis suis, thyroidinum – bovine, hgh) gel, NDC 61877-0007, labeler Natural Life Foods Corporation dba XYGENYX, marketing category "unapproved homeopathic," marketing start 18 September 2019
FDA National Drug Code directory and DailyMed label for SOMADERM, NDC 61877-0007 - marketing category "UNAPPROVED HOMEOPATHIC," labeler "Natural Life Foods Corporation dba XYGENYX," marketing start 18 September 2019; active ingredients Somatropin 30X, Glandula Suprarenalis Suis 6X, Thyroidinum (Bovine) 8X; full inactive-ingredient list; and the mandated disclaimer that the product has not been evaluated by the FDA for safety or efficacy
- SOMADERM Structured Product Label, full Drug Facts display including active and inactive ingredients and the homeopathic non-evaluation disclaimer
- FDA Warning Letters database, full-text search for "New U Life" - no warning letter to the company or to its label filer is returned
FDA warning-letter database and the agency’s 2019 health-fraud warning-letter compilation - searched directly and confirming the absence of any listed warning letter to this company or to the label filer
Not established by this document: The FDA warning-letter database search is citable and confirms the negative. The separate "2019 health-fraud warning-letter compilation" the prose refers to could not be resolved to a single stable fda.gov page and is not cited rather than guessed at.
- "Compliance Policy Guide Sec. 400.400 Conditions Under Which Homeopathic Drugs May Be Marketed; Withdrawal of Guidance," 84 FR 57439, Docket No. FDA-2019-N-4611, 25 October 2019
FDA withdrawal of Compliance Policy Guide Sec. 400.400, Federal Register notice of 25 October 2019, and the December 2022 risk-based homeopathic-drug enforcement guidance - the framework under which an unapproved homeopathic topical sits outside the agency’s highest enforcement priorities
- FDA final guidance, "Homeopathic Drug Products — Guidance for FDA Staff and Industry," December 2022, Docket No. FDA-2017-D-6580
- "Homeopathic Drug Products" final guidance, December 2022 (PDF full text)
- DSSRC Case #8-2019 (Monitoring Inquiry) - New U Life, decision published December 2019 / January 2020
DSSRC Case #8-2019 (Monitoring Inquiry), decided around January 2020 - unsupported health-benefit claims across the company website and distributor social media, and the finding that the disclosed $2,163.20 Associate-level average was "unusually high compared to other direct selling companies"; and DSSRC Case #16-2020 (Government Referral Report), closed 27 March 2020 - repeated failure to adhere to recommendations, COVID-19 claims by distributors, "systemic issues... could not be addressed in the context of industry self-regulation," and referral to the FTC and the FDA. BBB National Programs administers DSSRC; it is a private industry-funded self-regulator with no enforcement power
- DSSRC Case #16-2020 (Government Referral Report) - New U Life, referral to the FTC and the FDA, closed 27 March 2020
- BBB National Programs press release, "Direct Selling Self-Regulatory Council Refers Health-Related Product Claims by New U Life, Inc. to the Federal Trade Commission and the Food and Drug Administration," 7 April 2020
- FTC closing letter to counsel for Natural Life Foods Corp. d/b/a Strike First Nutrition, 5 August 2019 (FTC case page)
FTC closing letter of 5 August 2019 from the Associate Director, Division of Advertising Practices, to counsel for the founder concerning Natural Life Foods Corp. dba Strike First Nutrition and Testall Gel - staff investigated under Sections 5 and 12 of the FTC Act and decided not to pursue enforcement, citing modest sales volume and product discontinuation, while stating the closing is not a determination that no violation occurred
- FTC closing letter, Associate Director Mary K. Engle to counsel for Natural Life Foods Corp. d/b/a Strike First Nutrition re Testall Gel, FTC File No. 192-3065 (PDF)
- New U Life Corporation 2023 Distributor Compensation Summary (official Earnings Summary; all-distributor average $49.45, 140 PV / 5-week rolling active definition, expenses expressly not deducted)
New U Life official earnings summary, 2023 - all-distributor average of $49.45; Associate 99.44% at $1.05; Promoter 0.3% at $502.08; Coach $11,359.06; Life Coach $17,898.74; Ambassador $37,143.04; Diamond Ambassador $295,790.25; ranks above Promoter each under 0.1%; expenses expressly not deducted; figures apply only to distributors holding 140 PV in a rolling five-week period. Prior cycles: $2,163.20 Associate average in 2019 and $117.15 all-distributor average in 2021, the latter located only via secondary citation
- New U Life Corporation 2019 Distributor Compensation Summary (PDF, archived copy published by TINA.org)
- BehindMLM, "NewULife Review: Homeopathic human growth hormone gel" - compensation-plan teardown (binary 600/400 PV cycles at $40 and $60, 417-cycle weekly cap, 140/280 PV activity, seven-rank ladder and GV thresholds, $20/$60/$120 fast-start bonuses, retail commissions $45/$25/$520)
Independent compensation-plan teardown by the sector’s most granular MLM-plan reviewer - binary 600/400 PV matched cycles at $40 and $60, 417-cycle weekly cap, 140 PV/5-week activity requirement and 280 PV at Coach and above, the two-personally-sponsored-actives gate on binary eligibility, fast-start bonuses of $20/$60/$120, unilevel matching percentages by rank, coded recruitment-bonus pool percentages, the seven-rank ladder and its GV thresholds, car bonuses of $700 and $1,500 a month, and retail commissions of $45, $25 and $520
- New U Life US Compensation Plan Overview (official PDF) - five compensation methods, 600 GV / 400 GV cycle definition, $40 and $60 cycle values, rank qualification and matching-bonus percentages, $199/$499/$999 enrollment packs
- TINA.org complaint letter to the FTC Bureau of Consumer Protection and the FDA Health Fraud Branch re New U Life's deceptive marketing of Somaderm Gel, 5 September 2019 (PDF)
Private advertising-watchdog file - the September 2019 complaint letter to the FTC Bureau of Consumer Protection and the FDA Health Fraud Branch, the April 2020 supplemental complaint on COVID-19 claims, the standalone "FDA registered / FDA approved" claims evidence database, the January 2019 self-regulatory conclusion by the predecessor electronic-retailing program, and the reporting on the two February 2019 defamation suits and the internal-control litigation
Not established by this document: The ERSP Case #433 decision (23 January 2019) itself is no longer published at any retrievable URL - the Electronic Retailing Self-Regulation Program was wound up and its case archive is not on bbbprograms.org. It is cited here only through the BakerHostetler write-up and the DSSRC decisions that quote it.
- TINA.org supplemental complaint letter to the FTC and FDA re New U Life's coronavirus marketing, 8 April 2020 (PDF)
- TINA.org evidence database, "New U Life 'FDA Registered/Approved' Claims"
- New U Life, Inc. v. Hargett - defamation complaint, February 2019 (PDF copy published by TINA.org)
- Najjar v. Goldstein and New U Life, Inc., Contra Costa County Superior Court No. CIVMSC18-00581 - docket as of 26 August 2019, showing the 13 April 2018 order granting in part the preliminary injunction (PDF copy published by TINA.org)
- BakerHostetler (Goldstein and Mudge), "Hormone Gel Manufacturer Needs to Dial Back the Claims" - report of the January 2019 ERSP Case #433 decision on Somaderm
- California Secretary of State business entity record, NEW U LIFE CORPORATION, entity C4017199, domestic stock, registered 26 April 2017, Pleasant Hill (third-party mirror of Secretary of State data)
California business entity record for New U Life Corporation C4017199 via a third-party mirror of Secretary of State data; BBB business profile (A- grade, not accredited, one unanswered complaint); trade-press company profile of October 2020 (Pleasant Hill, Lehi and Taipei operations, approximately 395,000 distributors claimed, approximately $60 million first-year sales, self-funded); industry-aggregator revenue estimates of $272M/$250M/$250M/$250M/$150M/$128M for 2020–2025 and a 2025 payout-ratio estimate of about 35%, all unaudited
Not established by this document: The industry-aggregator revenue series ($272M/$250M/$250M/$250M/$150M/$128M for 2020–2025) and the ~35% payout-ratio estimate come from an unaudited trade aggregator; no single stable page carrying that whole series could be retrieved, so no URL is asserted for it.
- Better Business Bureau business profile, New U Life, 2623 Pleasant Hill Rd, Pleasant Hill, California (not BBB accredited)
- Direct Selling News, "New U Life: From Local Shop to Global Brand," 1 October 2020 - approximately $60m first-year sales, sales force of 395,000, Pleasant Hill / Lehi / Taipei offices, self-funded
What we could not get
- The exact entry-kit prices above the $199 tier. Sources conflict directly: one independent teardown gives $199/$499/$899 and two others give $199/$559/$999. Only the $199 basic tier is corroborated across all three, and this report does not silently pick a winner
- The annual renewal position. The kits are described as including a one-year membership, which implies a charge after year one, but no source reviewed quantified it and no company page stating it could be located. It is a material hole in any break-even model
- The current status and outcome of the internal-control litigation, Najjar v. Goldstein. The available docket reference dates to August 2019 and reports a preliminary injunction; nothing after that could be located
- The outcomes of the two defamation suits the company filed against former distributors in February 2019. Neither resolution could be found in any source reviewed
- The absence of any located action by overseas medicines regulators. The company has expanded into Canada, Australia and New Zealand, and no enforcement, product ban, safety alert or advertising ruling naming it was identified - but the enforcement portals of those regulators were not searched directly, so this is an absence of evidence and expressly not a clearance
- The current distributor headcount. The figure of approximately 395,000 comes from a trade-press profile of 2020 and no more recent official number could be located; in this industry "distributor" typically counts anyone who ever enrolled, not anyone currently active
- The revenue figures throughout this report. They are third-party unaudited estimates published by an industry aggregator, not company statements and not filed financials. The company is private and publishes no audited accounts. The trajectory is treated as directional and the precise dollar figures are not relied upon
- The current retail and autoship prices of the product, the current status of the NDC listing (which one mirror shows with a firm-discontinued end-marketing date), the founder’s self-described homeopathy and herbalism credentials, the claimed sixteen-year pre-MLM retail history, and the live California Secretary of State status of the corporation
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
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New U Life - frequently asked
QIs SomaDerm FDA approved?
QWhat did the FDA laboratory actually find in SomaDerm?
QHow much do New U Life distributors actually earn?
QWhat did the 2020 DSSRC referral to the FTC and FDA lead to?
QIs New U Life a pyramid scheme?
Author, editor and publisher
This report was researched and written by Claude, Anthropic’s AI assistant, working from primary documents - New U Life’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
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Corrections
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