- Claim:
- That the earnings table on a company's income disclosure statement tells you what a typical participant earns.
- Population:
- Herbalife's one-page statement of US Distributor earnings for 2025
- Earned money in a typical month, the group the table describes
- about 47,000
- Ordered products for resale in 2025
- about 107,769
- Half of All Other Distributors earned more than, per month, before expenses
- $320
- Cost of the starter kit, the only required purchase
- $54.95
- Finding:
- read line by line, Herbalife's 2025 statement describes a narrower group than the reader is asked about. The table covers about 47,000 Distributors who earned money in a typical month, out of about 107,769 who ordered products for resale, and its dollar figures are monthly cut-offs before expenses. The statement gives no total number of Distributors.
- Confidence:
- High for what the document prints, because every figure is copied from Herbalife's own one-page statement, fetched on 3 November 2026. Low for anything the document does not print, which is the point of this autopsy.
- Docket:
- U.S. Statement of Typical Distributor Earnings 2025
Inconclusive: the documents cannot settle the claim yet. What would change this verdict
Verdict: Inconclusive
The claim
The question an income disclosure statement seems to answer is simple: if I join, what will I make? The statement’s own heading frames it that way. Herbalife’s U.S. Statement of Typical Distributor Earnings 2025 opens with “KEY INFORMATION ABOUT BEING AN HERBALIFE INDEPENDENT DISTRIBUTOR” and asks, in its margin, “How much can a Distributor earn in a typical month?”
The steelman deserves its full weight. The statement is short, current and easy to find: it is printed “Published: June 2026”, it covers calendar 2025, and Herbalife’s own business opportunity page links it. It gives percentiles rather than a flattering average. It names the cost of joining, “$54.95”, and says “There is no other required purchase.” It tells the reader plainly that “The majority of Distributors in 2025 joined only to receive a discount on Herbalife® products and do not sell products or recruit others.” And it says what most disclosures leave to small print: “There are no guarantees for success.”
It is also not required. The FTC’s business guidance on multi-level marketing, which describes itself as “non-binding guidance” from Commission staff, says: “If an MLM is not a “Business Opportunity,” it is not required to give any information about earnings to potential participants, but any earnings information it does give must be truthful, substantiated, and non-misleading.” The industry’s self-regulator, DSSRC, opens its guidance on income disclosure statements with “Although not required by law”. A company that publishes one is doing something voluntary.
So the claim examined here is not whether the statement is honest. It is whether its table answers “what will I make?” To find out, I read it the way you would read a contract: who is counted, over what period, and before or after what.
The evidence
The statement prints three headcounts in one sentence, each inside the last:
“In 2025, about 107,769 U.S. Distributors ordered products for resale from Herbalife and about 96,000 of them earned money from their sales and the sales of those they sponsored. In a typical month, about 47,000 earned money, including those making supplemental income. Here is what they earned in a typical month before expenses:”
The table that follows splits the third group in two: “First-Year Distributors (about 6,000)” and “All Other Distributors (about 41,000)”. Those two add to 47,000, which matches the sentence.
The groups Herbalife's 2025 statement counts, on one headcount scale
Now the definitions, one line at a time.
Who is counted. The widest group is Distributors who “ordered products for resale”. The statement says the majority “joined only to receive a discount”, and it gives no count for them, so the total number of Distributors is not on the page. The table then narrows to people who “earned money” “in a typical month”. By my arithmetic, about 47,000 out of about 107,769 is about 44% of the resale group. That share is mine, not Herbalife’s, and both inputs are rounded.
What the dollars are. Each row is a threshold. The All Other column reads: “50% (about 20,500) earned more than $320 in a month”, “Top 10% (about 4,100) earned more than $5,442 in a month” and “Top 1% (about 410) earned more than $21,893 in a month”. The First-Year column: “50% (about 3,000) earned more than $166 in a month”, “Top 10% (about 600) earned more than $1,174 in a month” and “Top 1% (about 60) earned more than $5,552 in a month”. Neither “average” nor “median” appears in the document. The 50% row works like a median for that group, but that is my reading; the company does not call it one.
The six monthly cut-offs in the earnings table, before expenses, on one dollar scale
Over what period. The dollars are “in a month”, for people who earned in “a typical month”, a phrase the statement uses twice and never defines. The column headers add how often people earned at all: the First-Year group, “about half earned in two months or more in 2025”; the All Other group, “about half earned in seven months or more in 2025”. So many of the months in that year were not earning months for these people. The FTC staff page warns against exactly the shortcut a reader is tempted to take: a statement “should not misrepresent participant earnings, including by annualizing or projecting income that was not actually earned”. The $320 is not $3,840 a year, and Herbalife never says it is.
Before what. Everything is “before expenses”. The only costs printed are the $54.95 starter kit and a one-product retail example: “Suggested Retail price $61.75 Distributor price - $47.68”, “Potential profit $14.07”. The DSSRC guidance names the reason companies rarely go further: they “may not have access to information about the expenses incurred by their salesforce members”. Whatever the reason, no net figure can be worked out from this page.
How long the top takes. One line gives tenure, and only for the top: “In 2025, the tenure of the Top 1% typically ranged from five to 12 years.” No tenure is printed for the 50% or top 10% rows.
The same reading on two other statements
The value of reading line by line shows when you put a second document next to the first. Each company defines its own group, and the groups do not match.
LifeVantage’s U.S. Income Disclosure Statement, revised 02/03/2025 and covering calendar 2024, starts from everyone who could earn: “During the Period, there were a total of 54,531 U.S. Consultants who had the opportunity to earn commissions under the Evolve Compensation Plan. Of these, 35.52% earned commissions while 64.48% did not.” It prints that denominator and then, in its own words, “Consultants who did not earn commissions during the Period are not reflected in the table below.” Its headline is a 12-month figure for earners only: “The median 12-month earnings of all Consultants who earned during the Period was $186.”
USANA’s 2023 United States Income Disclosure Statement, the newest US edition I could find, draws the widest circle: “In 2023, there were a total of 23,336 active* USANA Associates and Affiliates in the United States”, where the asterisk reads “Includes all Associates/Affiliates who made at least one purchase in 2023.” Its table reports its own definition of “net profit”, and 72.6% of that group sit in the “$0 to $250” band for the year.
| Herbalife | LifeVantage | USANA | |
|---|---|---|---|
| Year covered | 2025 | 2024 | 2023 |
| Who is counted | ordered products for resale, then earned in a typical month | had the opportunity to earn, then only those who earned | made at least one purchase |
| Time unit | a month | 12 months | a year |
| Gross or net | before expenses | gross | net profit, as USANA defines it |
| The headline | half of All Other earned more than $320 in a month | median of earners, $186 | 72.6% in $0 to $250 |
Three documents, three bases, three time units. Each sentence above is true of its own document, and none of the three headline numbers can be compared with the others. The FTC staff report on 70 statements found the same thing across the industry: “Where definitions are provided, they are not consistent from one MLM to another, increasing the chances for confusion.” That report is the subject of our reading of the 70 disclosures; here it is enough that its sentence fits these three.
What the evidence supports, and what it does not
Supported. That Herbalife’s statement, printed “Published: June 2026” and linked from its US business opportunity page, says about 107,769 US Distributors ordered products for resale in 2025, about 96,000 of them earned money, and about 47,000 earned money in a typical month, and that its six dollar rows describe that last group in monthly cut-offs before expenses. Every figure is quoted above as printed.
Supported. That the statement prints no total number of Distributors and no count for the majority who “joined only to receive a discount”.
Supported, and worth saying. That this is a readable statement. It is one page with no footnotes, it gives percentiles rather than a single flattering mean, it shows a first-year group separately, it prints the joining cost, and it says in plain words that most Distributors are discount buyers. Scentsy’s disclosure, which we read in August, earned a CONFIRMED stamp for answering its own question. This one answers its own question too. Its question is just narrower than the one on the reader’s mind.
Not supported: that $320 is what a typical Distributor earns. It is the point that half of about 41,000 people who earned in a typical month exceeded, in a month, before expenses. It says nothing about the people outside the table, and nothing about profit.
Not supported: any profit or loss for anyone. The statement is gross. No expense figure beyond the kit and one retail example is printed, so neither a gain nor a loss can be read from it.
Not supported: that the statement breaks any rule. The FTC page is staff guidance and calls itself non-binding, and the DSSRC text is industry self-regulation. Whether a given MLM falls under the Business Opportunity Rule is, in the FTC’s words, decided “on a case-by-case basis”. I make no finding about Herbalife, LifeVantage or USANA, and none is implied.
Not supported: a trend. The statement covers one year. I did not fetch an earlier Herbalife edition, so I cannot say whether these figures rose or fell.
Cause of death
What dies here is a habit: reading the first number on an earnings table as an answer to “what will I make?”
The table answers a different question. It tells you what people who earned something, in a month when they earned, earned before they paid for anything. That is real information, and Herbalife prints it clearly. But between “people who joined” and “people in the table” sit at least two filters, ordered for resale, and earned in a typical month, and only the second group gets dollar figures. The FTC staff page asks statements to “clearly and prominently explain what data is contained in the document”. Read line by line, this one does, as long as you read every line. The headcount sentence above the table is the one that matters most.
What would change this verdict
The verdict is INCONCLUSIVE because the document cannot settle the reader’s question, not because anything in it is wrong. Four additions would settle more of it:
- The total. How many US Distributors there were in 2025, including the discount-only majority. With that one number, every share on the page would have a base.
- A definition of “a typical month”. An average month, a median month, a named month: any of them would tell a reader what the $320 row stands for.
- The year, not just the month. Annual earnings for the 107,769, the way LifeVantage prints its 12-month median, would remove the temptation to multiply by 12.
- An expense estimate. Even a rough figure for typical costs would turn a gross table into something close to an answer.
None of that is owed. Until then, the method is the same for any statement: find the sentence that says who is counted, find the time unit, find the words “before expenses”, and only then read the dollars.
Frequently asked questions
Does US law require an MLM to publish an income disclosure statement?
Not as a general rule. The FTC's own guidance says an MLM that is not a Business Opportunity under 16 C.F.R. § 437.1 is not required to give any earnings information, but any it does give must be truthful, substantiated and non-misleading. The industry's self-regulator, DSSRC, calls the statement not required by law.
What does the $320 in Herbalife's statement mean?
It is a cut-off, not an average. Half of the about 41,000 All Other Distributors who earned money in a typical month of 2025 earned more than $320 in a month, before expenses.
How many Herbalife Distributors are counted in the earnings table?
About 47,000: the Distributors who earned money in a typical month of 2025. The statement says about 107,769 US Distributors ordered products for resale that year, and it prints no total number of Distributors.
Can I compare Herbalife's figures with LifeVantage's or USANA's?
Not directly. Herbalife counts people who ordered for resale and reports monthly cut-offs before expenses, LifeVantage reports 12-month figures only for Consultants who earned commissions, and USANA counts anyone who made at least one purchase and reports its own definition of net profit.
Source docket
- Herbalife, “U.S. Statement of Typical Distributor Earnings 2025”, printed “Published: June 2026”, covering calendar 2025: https://www.herbalife.com/content/dam/global-reusable-assets/documents/pd-statement-typical-distributor-earnings-en-us.pdf (fetched 3 November 2026). Linked from https://www.herbalife.com/en-us/business-opportunity.
- US Federal Trade Commission staff, “Business Guidance Concerning Multi-Level Marketing”, FAQ 23 and 24: https://www.ftc.gov/business-guidance/resources/business-guidance-concerning-multi-level-marketing
- Direct Selling Self-Regulatory Council, “Guidance on Income Disclosure Statements for the Direct Selling Industry”: https://assets.bbbprograms.org/docs/default-source/dssrc/dssrc_guidanceonincomedisclosures_digital.pdf
- LifeVantage, “U.S. Income Disclosure Statement”, revised 02/03/2025, covering 1 January to 31 December 2024: https://www.lifevantage.com/legal/us-en/income-disclosure-statement
- USANA, “2023 United States Income Disclosure Statement”: https://www.usana.com/static/images/na/Training/ComplianceCorner/IncomeDisclosureStatement-US-EN.pdf
- US Federal Trade Commission staff, “Multi-Level Marketing Income Disclosure Statements: An FTC Staff Report”, September 2024: https://www.ftc.gov/system/files/ftc_gov/pdf/mlm-ids-report.pdf
Related autopsies: Scentsy’s $466.56 median, PlanNet’s $38.15, and 70 MLM income disclosures read in bulk.