
Date: 27 November 2025
Status: Expert public-health opinion based on independently verifiable scientific and legal sources (regulatory registers, official APLGO websites, peer-reviewed literature) and PHIG’s review of APLGO marketing practices in Georgia
1. Mandate and scope of this statement
The Public Health Institute of Georgia (PHIG) is an independent, non-commercial public-health organization. Our mandate is to:
- Protect population health and prevent avoidable harm;
- Promote evidence-based practice in medicine, nutrition and consumer health;
- Support Georgian regulators and consumers in identifying misleading or unsafe health-related products.
This statement evaluates APLGO® and its proprietary lozenge (“drop”) products marketed under the Acumullit SA® technology, with specific reference to:
- how APLGO itself describes Acumullit SA® and its products globally and in Georgia;
- the scientific plausibility of the technology’s claimed mechanisms (e.g. “nano-particles”, “plant stem cells”, “cellular self-regulation”);
- documented disease-cure and safety claims made by APLGO distributors in Georgia on social media;
- applicable Georgian, EU and US regulations on food supplements and advertising;
- the public-health risks associated with these marketing practices.
This document is not a legal ban and does not replace the authority of Georgian governmental bodies (National Food Agency, State Regulation Agency for Medical Activities, Competition and Consumer Agency, Georgian National Communications Commission, etc.). It is an independent expert risk assessment and policy position issued in the public interest.
2. APLGO® and Acumullit SA® products in Georgia
APLGO is an international multi-level marketing (MLM) company that sells chewable “drops” (lozenges) based on plant extracts. The global APLGO landing page describes the company as a “GO Style” enterprise with “products that change the world”, and lists Acumullit SA® as its core technology.1,8,15,16
On the Acumullit SA® pages of several APLGO country websites (including South Africa, Czech Republic and France), the technology is described as follows:1,8,15,16
- “In our Acumullit SA® technology we use exclusive plants from around the world mixed in a unique formula for each product. The parts of the plants (leaves, roots, flowers, fruits, seeds) are selected to complement each other.”
- “The Acumullit SA® technology allows the beneficial properties of the whole food botanical ingredients to be preserved and enhanced.”
- “A state-of-the-art extraction process triggers the activation of the botanical compounds, so that nano-particles of the active compounds can be isolated without other substances in the plant.”8,15
In Georgia, APLGO operates through the local company შპს ალგო (SHPS ALGO), with a registered address in Tbilisi (ვაჟა-ფშაველას გამზირი N49, კორპუსი 15, ბინა 16), as shown in the footer of the Georgian site https://ge.aplgo.com.2,5,9,13,17 The Georgian-language site provides corporate contact details and promotions but does not provide detailed Georgian-language monographs for each product; instead, distributors often rely on translated or unofficial materials and social media content.
Outside Georgia, some APLGO products have been formally registered as food supplements by regulatory authorities. For example, the Philippines FDA lists:4,6,14
- MLS Herbal Proprietary Blend Dietary Supplement Lozenges (APLGO MLS), categorised as a “High Risk Food Product” and explicitly marked “Registered as Food Supplement with NO APPROVED THERAPEUTIC CLAIMS”;4
- ALT Herbal Proprietary Blend Dietary Supplement Lozenges – Taste of Black Currant Berry (APLGO ALT), likewise registered as a high-risk food supplement with “NO APPROVED THERAPEUTIC CLAIMS”;6
- GTS Herbal Proprietary Blend Dietary Supplement Lozenges – Pineapple Flavour (APLGO GTS), also registered as a high-risk food supplement with the same “no approved therapeutic claims” disclaimer.14
On the French APLGO site, the company’s policy section explicitly states (our translation): “Les produits d’Acumullit SA ne sont pas destinés à prévenir ou à traiter des problèmes de santé” – “Acumullit SA products are not intended to prevent or treat health problems” – and warns associates that mentioning treatment or prevention of health problems, including COVID-19, is strictly prohibited by company policy.12
Taken together, APLGO’s own global documentation and official registrations (e.g. Philippines FDA) confirm that:
- APLGO products are legally classified as food supplements, not medicines;
- they have no approved therapeutic claims in at least one major jurisdiction; and
- corporate policy forbids describing them as intended to prevent or treat health problems.
3. Scientific assessment of Acumullit SA® claims
3.1. “Nanoparticles” and oral delivery
Legitimate nanotechnology research for oral delivery of drugs and nutrients focuses on well-characterised nanomaterials (e.g. polymeric nanoparticles, lipid nanoparticles, nano-emulsions) designed to improve stability and absorption of specific agents. Reviews in Advanced Drug Delivery Reviews, Pharmaceutics and related journals discuss the design, evaluation and safety of such systems.7–9
In contrast, Acumullit SA® promotional text on APLGO’s sites simply states that an extraction process “triggers the activation of botanical compounds so that nano-particles of the active compounds can be isolated without other substances in the plant.”8,15 No further details are provided on:
- the physicochemical characteristics (size, composition, stability) of these alleged “nano-particles”;
- their toxicology or dose-response;
- clinical trials in humans.
A search of PubMed, ClinicalTrials.gov and other major biomedical databases identifies no human clinical trials or toxicology studies evaluating Acumullit SA® products for any disease or outcome. This stands in sharp contrast to the marketing claims observed in Georgia (see Section 4).
3.2. “Plant stem cells” and “smart food”
Georgia-based APLGO distributors frequently describe Acumullit SA® drops as:
- “მცენარეული ღეროვანი უჯრედების” (plant stem cells) based;
- “უჯრედული კვება” (cellular nutrition) that carries “control information” allowing the body to “activate programmed self-regulation systems”;
- “ჭკვიანი საკვები” (“smart food”) that rejuvenates and regenerates organs at the cellular level.
However, scientific literature on stem-cell therapy and nanotechnology in regenerative medicine describes the use of mammalian stem cells (e.g. mesenchymal stem cells), scaffold materials and nanostructured delivery systems in tightly controlled lab and clinical settings – not oral lozenges containing dried plant extracts.10–12 There is no recognised biomedical mechanism by which:
- “plant stem cells” consumed orally could engraft, differentiate or regenerate human tissues; or
- lozenges could “program” human cells via “information codes” as claimed in APLGO marketing.
PHIG therefore concludes that Acumullit SA® mechanistic claims go beyond known science and lack credible biomedical support. At best, the products can be considered conventional herbal supplements with speculative mechanistic narratives layered on top.
4. Documented disease-cure and safety claims in Georgia
Although APLGO’s corporate policies and some country websites (e.g. France) forbid disease claims,12 PHIG’s review of Georgian-language APLGO marketing reveals a large volume of social-media content that directly contradicts these policies. The following examples reproduce the substance of claims seen in Georgian posts (screenshots on file at PHIG), with product codes preserved as in those posts:
- ALT – “ალტი”: advertised as “allergy treatment; cleans blood and lymph; removes toxins, slags, carcinogens, heavy metals, radionuclides; neutralises harmful effects of chemotherapy; cleanses the skin and fights skin diseases such as eczema and psoriasis; useful for upper respiratory tract and bronchial asthma.”
- MLS – “მელსი”: described as “the strongest natural antibiotic; contains 40 antibacterial plants; cleans the body at the cellular level of viruses, bacteria and fungi; neutralises streptococcus and staphylococcus; fights Helicobacter pylori; has strong anti-parasitic action; protects against 250 types of parasites by creating an environment where they cannot multiply.”
- HPR – “ხეპერი”: marketed as “liver cleansing and regeneration; protects hepatocytes from degeneration; improves metabolism in the liver; protects from inflammatory and viral liver diseases; removes toxins from the body.”
- SLD – “სლაიდი”: promoted as “first aid for the musculoskeletal system; treats inflammation of bones and joints; treats spinal hernia, osteoporosis, arthritis; restores synovial fluid; activates elastin and collagen synthesis; prevents cartilage damage and joint swelling; accelerates bone healing after fracture, injury or surgery.”
- STP – “სტოპი”: claimed to “restore microcirculation in capillaries; thin the blood; relieve pain and fight inflammatory processes.”
- HRT – “ხარტი”: said to “help cardiovascular system; prevent formation of thrombi; lower blood pressure; nourish the heart; clean blood vessels and make vessel walls elastic.”
- NRM – “ნორმი”: advertised as “normalises blood sugar; regulates neuroendocrine system; supports carbohydrate metabolism.”
- RLX – “რელაქსი”: promoted as “calms nervous system; fights insomnia, irritability, anxiety, tensions, fears and panic attacks; neutralises stress hormones; restores all phases of sleep so that the body wakes rested; gives confidence.”
- HPY – “ჰეპი”: marketed as a “natural antidepressant; helps with concentration and depression; anti-schizophrenia.”
- GRW – “გროუ”: described as “immune-system strengthener; polyvitamin complex with 350 active components; protects against seasonal illnesses; has immunomodulatory action.”
- PWR man / PWR woman – “პაუერი”: claimed to improve “male and female reproductive system health; potency and libido; prostate protection; hormonal balance; menstrual cycle regulation; eases menopause; protects urinary and genital systems from diseases.”
- BTY – “ბიუთი”: promoted as an “elixir of beauty and youth” that “improves skin elasticity and health; fights wrinkles; activates collagen and elastin synthesis; strengthens nails; prevents hair loss by activating hair follicles; removes almost all skin diseases; slows ageing and keeps a youthful appearance.”13
- BRN – “ბრეინი”: described as “brain cell nutrition and protection; restores neuronal connections; improves memory and learning; activates cerebral circulation; improves cognitive abilities and creativity.”
One widely circulated Georgian post describes a young man with severe psoriasis, stating (translated): “This young man’s body was covered with psoriasis for 6 years; doctors said it is incurable… After 4 months on ALT, MLS, HPR, RLX and SLD drops, psoriasis disappeared completely. All these products worked synergistically and the result is visible!!!” – accompanied by before/after photos suggesting cure.14
Other posts explicitly state that APLGO products:
- “have a final healing effect, therefore we give them as programmes”;
- “can be taken for all diseases and all age groups”;
- “do not cause dependency, have no side effects, and there is no risk of overdose.”
These are clear disease-cure and absolute-safety claims, which:
- directly contradict APLGO’s corporate policies (e.g. French website explicitly stating products are not intended to prevent or treat health problems);12
- are incompatible with Georgian and EU rules on food-supplement advertising; and
- are not supported by published clinical evidence.
5. Regulatory and legal analysis
5.1. Georgia
The Law of Georgia on Advertising (1998, as amended) prohibits misleading, unfair or clearly false advertising, and forbids attributing to foods or food supplements the property of preventing, treating or curing human diseases, or referring to such properties. It also prohibits implying that products have no side effects or are universally effective for all people.
APLGO-related Georgian posts that:
- explicitly claim to cure psoriasis, allergies, viral and bacterial infections, parasitic infestations, diabetes, cardiovascular disease, depression, panic attacks, osteoporosis, spinal hernia and many other conditions; or
- state that the products can be used “for all diseases and all ages” with “no side effects and no risk of overdose”;
are incompatible with these legal standards and should be viewed as high-risk, potentially unlawful advertising.
5.2. European Union
In the EU, food supplements are regulated under Directive 2002/46/EC and may carry only authorised health claims per Regulation (EC) No 1924/2006. European guidance on food supplements makes clear that:15,16
- food-supplement labels and advertising must not attribute to the supplement the property of preventing, treating or curing a human disease, or refer to such properties;
- supplements must not give the impression that they are a substitute for a varied diet or for medical treatment;
- labels should include warnings not to exceed recommended doses.
APLGO’s official French policy text explicitly reiterates these limits: “Les produits d’Acumullit SA ne sont pas destinés à prévenir ou à traiter des problèmes de santé… You must not suggest directly or indirectly that our products are intended to treat or prevent any health problem, including COVID-19 – this is strictly forbidden and violates company policy.”12
The Georgian distributors’ claims described above – asserting treatment of specific medical conditions, “final healing effect” and absence of side effects or overdose risk – would clearly constitute illegal medicinal claims if made within EU territory.
5.3. United States and other markets
Under US law (Dietary Supplement Health and Education Act; FDA and FTC guidance), dietary supplements:
- may not be marketed as drugs to diagnose, treat, cure or prevent diseases without prior FDA approval;5–7,23,26
- must have health-related statements supported by “competent and reliable scientific evidence”;
- must include the standard disclaimer when structure/function claims are used.
While APLGO has not, to PHIG’s knowledge, been the subject of US enforcement specific to its health claims, the company was among the recipients of the FTC’s October 2021 “Notice of Penalty Offenses” concerning money-making opportunities and deceptive endorsement practices – a formal warning that future violations could incur civil penalties.6
The Philippines FDA classification of MLS, ALT and GTS as high-risk food supplements with “No Approved Therapeutic Claims” reinforces that, at least in one regulated market, APLGO’s products are recognized as supplements without therapeutic status.4,6,14
6. Public-health risks in Georgia
PHIG identifies several public-health risks associated with APLGO’s marketing in Georgia:
- Delay of appropriate medical care: When chronic and serious conditions (psoriasis, asthma, cardiovascular disease, diabetes, depression, panic disorder, joint disease, autoimmune disease) are treated with unproven APLGO products instead of evidence-based medicine, diagnosis and effective therapy may be delayed or foregone.
- False sense of safety: Claims that APLGO products have “no side effects” and “no risk of overdose” contradict basic pharmacological and toxicological principles, and may encourage excessive or unsupervised use, including in children and elderly people.
- Use in vulnerable populations: Marketing phrases such as “for all diseases and all ages” encourage use in high-risk groups (children, pregnant women, persons with multiple chronic diseases) without medical supervision.
- Pseudoscientific narratives: Terms such as “DNA candies”, “plant stem cells”, “cellular programming” and “smart food with control information” can mislead non-expert audiences into overestimating the technological sophistication and evidence base of these products.
- MLM-driven pressure: As with other MLM schemes, financial incentives may push distributors to exaggerate benefits, understate risks and rely on unverifiable testimonials (e.g. dramatic “before/after” photos) rather than transparent, high-quality evidence.
7. PHIG’s official position on APLGO® / Acumullit SA® in Georgia
Based on the evidence and legal context described above, PHIG issues the following position (27 November 2025):
PHIG does not recommend the use of APLGO® / Acumullit SA® products for the diagnosis, treatment, cure or prevention of any medical condition. These products should not be used as an alternative to evidence-based medical care, prescribed medicines or medically supervised treatment programmes.
In particular:
- No peer-reviewed clinical trials were identified that demonstrate efficacy of APLGO products for psoriasis, allergies, infections, liver disease, joint disease, cardiovascular disease, metabolic disorders, neurological or psychiatric conditions, hormonal disorders or any other pathology.
- Claims of “final healing effect”, effectiveness “for all diseases and all ages” and “no side effects or overdose risk” are scientifically untenable and may endanger patients.
- Core mechanistic claims about “plant stem cells”, “nanoparticles” and “cellular programming” are not supported by contemporary biomedical science and appear to be marketing narratives rather than evidence-based mechanisms.
- The use of before/after medical photographs and disease-cure testimonials in APLGO marketing constitutes misleading health advertising and is likely to violate Georgian and EU advertising law.
8. Recommendations to Georgian regulators
8.1. National Food Agency and health authorities
- Review the registration status, labelling, composition and quality documentation of APLGO / Acumullit SA® products imported or marketed in Georgia;
- Ensure that labels clearly state that the products are food supplements, not medicines, and that they have no approved therapeutic claims;
- Consider targeted sampling and laboratory analysis of selected products and independent verification of manufacturing facilities and certificates where needed.
8.2. Competition and Consumer Agency
- Investigate Georgian-language disease-cure and absolute-safety claims made by APLGO distributors on social media and other channels;
- Require corrective action (removal or amendment of misleading posts, clearer disclaimers) and, where appropriate, impose sanctions for repeated or egregious violations.
8.3. Georgian National Communications Commission (GNCC)
- Monitor broadcast and digital content (including influencer marketing) for covert or disguised APLGO advertising presented as neutral health advice;
- Ensure that any paid or incentivised content featuring APLGO products is clearly labelled as advertising and does not imply medically proven efficacy.
9. Annex – Related PHIG assessments
This APLGO position statement is part of a broader series of independent, evidence-based assessments carried out by PHIG on international supplement and MLM-type brands in Georgia. For comparison, PHIG recommends the following documents on https://supplement.ge:
- Greenway® NEORESERVO® Resveratrol Gel and Disease-Cure Claims in Georgia – PHIG Position
- JIFU® LIV™ Glutathione Supplement and Autism Claims in Georgia – PHIG Position
- Amvilab® and the Product “Amevit Kids” in Georgia – PHIG Position
- PHIG Position Statement on Orthomol® Food Supplements in Georgia
Together with the present APLGO document, these assessments provide a comparative picture of how different global supplement brands and MLM structures present themselves in Georgia, the types of health and income claims they make, and the public-health implications of those practices. PHIG encourages journalists, clinicians, policy-makers and the public to use these resources – alongside https://www.sheniekimi.ge and https://www.sheniambebi.ge – when evaluating any commercial health product.
10. Legal and evidentiary robustness of PHIG’s position
PHIG’s assessment is grounded in:
- APLGO’s official materials describing Acumullit SA® as a botanical extraction technology and its products as dietary supplements, not medicines;1,8,15,16
- APLGO’s own policy statements (e.g. French site) explicitly forbidding disease-prevention and treatment claims for Acumullit SA® products;12
- Philippines FDA registrations classifying MLS, ALT and GTS as high-risk food supplements with “No Approved Therapeutic Claims”;4,6,14
- International scientific literature on nanotechnology and stem-cell therapies, demonstrating that credible nanomedicine and cell therapy involve controlled, well-characterised systems quite unlike the marketing narratives used for Acumullit SA® drops;7–12
- Publicly available Georgian-language posts by APLGO distributors, which clearly and repeatedly make disease-cure and absolute-safety claims in conflict with both APLGO’s official policies and Georgian/EU advertising rules;13,14
- PHIG’s own database searches confirming the absence of human clinical trials or toxicology studies for Acumullit SA® products.
On this basis, and in line with the precautionary principle and consumer-protection norms, PHIG concludes that APLGO® / Acumullit SA® products, as currently promoted in Georgia, present a substantial risk of consumer deception and of delayed or inadequate medical care. PHIG therefore publicly advises against relying on these products for any medical purpose and calls for regulatory scrutiny of their marketing and distribution.
References (Vancouver style, with full URLs)
- APLGO World. APLGO – Products that change the world [Internet]. 2025 [cited 2025 Nov 27]. Available from: https://world.aplgo.com/
- APLGO Georgia. APLGO – Official Georgian site [Internet]. Tbilisi (GE): შპს ალგო; 2025 [cited 2025 Nov 27]. Available from: https://ge.aplgo.com
- APLGO South Africa. Acumullit SA® – ZA [Internet]. 2025 [cited 2025 Nov 27]. Available from: https://za.aplgo.com/en/acumullitsa/
- Philippines Food and Drug Administration. MLS Herbal Proprietary Blend Dietary Supplement Lozenge (APLGO MLS) – High Risk Food Products View [Internet]. 2022 Apr 6 [cited 2025 Nov 27]. Available from: https://verification.fda.gov.ph/FoodProduct_Highriskview.php?ACCOUNTCODE=FR-4000009166026&showdetail=
- APLGO Georgia. ვინ ვართ ჩვენ (“Who we are”) [Internet]. Tbilisi (GE): შპს ალგო; 2025 [cited 2025 Nov 27]. Available from: https://ge.aplgo.com/ka/who-we/
- Philippines Food and Drug Administration. HERBAL PROPRIETARY BLEND DIETARY SUPPLEMENT LOZENGES – Taste of Black Currant Berry (APLGO ALT) – High Risk Food Products View [Internet]. 2022 Apr 5 [cited 2025 Nov 27]. Available from: https://verification.fda.gov.ph/FoodProduct_Highriskview.php?ACCOUNTCODE=FR-4000009149632&showdetail=
- Akhter A, et al. Nanoparticles for oral delivery: design, evaluation and state of the art. Adv Drug Deliv Rev [Internet]. 2016;106:17–39 [cited 2025 Nov 27]. Available from: https://www.sciencedirect.com/science/article/pii/S0169409X16300365
- APLGO South Africa. Acumullit SA® technology description [Internet]. 2025 [cited 2025 Nov 27]. Available from: https://za.aplgo.com/en/acumullitsa/
- APLGO Europe (Czech). Acumullit SA® – Daily Collection [Internet]. 2025 [cited 2025 Nov 27]. Available from: https://cz.aplgo.com/en/acumullitsa/
- Wang J, et al. Research progress in cell therapy for oral diseases. Front Bioeng Biotechnol [Internet]. 2024;12:1340728 [cited 2025 Nov 27]. Available from: https://www.frontiersin.org/articles/10.3389/fbioe.2024.1340728/full
- Masoudi Asil SM, et al. Nanotechnology-enabled advances in oral delivery of therapeutic peptides: mechanistic insights for translation to clinic. Appl Sci [Internet]. 2020;10(14):4852 [cited 2025 Nov 27]. Available from: https://www.mdpi.com/2076-3417/10/14/4852
- APLGO France. Company policy notice: “Les produits d’Acumullit SA ne sont pas destinés à prévenir ou à traiter des problèmes de santé” [Internet]. 2020 [cited 2025 Nov 27]. Available from: https://fr.aplgo.com/
- APLGO. BTY – Beauty Acumullit SA® product information [Internet]. 2025 [cited 2025 Nov 27]. Available from: https://aplgo.com/j/514233/acumullitsa/bty/
- APL_GO_GEORGIA. Facebook psoriasis testimonial (ALT, MLS, HPR, RLX, SLD) [Internet]. 2022 [cited 2025 Nov 27]. (Screenshots on file at PHIG).
- Food Safety Authority of Ireland. Food supplements – legislative requirements [Internet]. Dublin (IE); 2023 [cited 2025 Nov 27]. Available from: https://www.fsai.ie/getmedia/423fabe9-1f36-4fef-bbd4-bd142799758b/food-supplements-legislative-requirements.pdf
- European Commission. Guidance document on the implementation of certain provisions of Regulation (EC) No 1924/2006 [Internet]. Brussels (BE); 2017 [cited 2025 Nov 27]. Available from: https://food.ec.europa.eu/system/files/2020-02/labelling_nutrition-supplements-adm_guidance_safety_substances_en.pdf
- Philippines Food and Drug Administration. HERBAL PROPRIETARY BLEND DIETARY SUPPLEMENT LOZENGES – Pineapple Flavour (APLGO GTS) – High Risk Food Products View [Internet]. 2022 Apr 8 [cited 2025 Nov 27]. Available from: https://verification.fda.gov.ph/All_FoodProductsview.php?ACCOUNTCODE=FR-4000009165922&showdetail=
- Parliament of Georgia. Law of Georgia on Advertising [Internet]. 1998 Feb 18 [cited 2025 Nov 27]. Available from: https://assets.tobaccocontrollaws.org/uploads/legislation/Georgia/Georgia-Law-on-Advertising.pdf
- Georgian National Communications Commission (GNCC). Regulation of broadcast advertising [Internet]. Tbilisi (GE); 2015 [cited 2025 Nov 27]. Available from: https://comcom.ge/uploads/other/2/2522.pdf

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