# Source: An Economic Analysis of Utah's Direct Selling Industry (Gardner Institute, 2022)

**Type:** source
**Status:** Draft
**Confidence:** Medium
**Source Type:** reference
**URL:** https://gardner.utah.edu/wp-content/uploads/DirectSales-Aug2022.pdf
**Archive:** https://web.archive.org/web/20260506222134/https://d36oiwf74r1rap.cloudfront.net/wp-content/uploads/DirectSales-Aug2022.pdf
**Archived:** 2026-05-06
**Publisher:** Kem C. Gardner Policy Institute, University of Utah
**Retrieved:** 2026-08-12
**Raw:** raw/gardner-utah-direct-selling-analysis-2022/2026-08-11-d0bd0399b226.txt
**Published:** 2022-08-16
**Updated:** 2026-08-11

## Summary

A 24-page study of Utah's direct-selling industry by the Kem C. Gardner Policy Institute at the
University of Utah, **commissioned by the Utah Direct Selling Coalition and the Governor's Office of
Economic Opportunity**. It is the only published attempt to size the industry as a Utah cluster
rather than company by company, and the source of the figures that circulate as "Utah is the
direct-selling capital."

It rests on three legs of very different strength. Employment and wages come from custom
aggregations by the Utah Department of Workforce Services — administrative payroll data, the solid
leg. Sales, sales-representative counts, and representative earnings come from a **survey of 12
Utah companies administered by Dorsey & Whitney LLP**, an industry law firm, with 10 responding and
answers de-identified before the researchers saw them; those numbers are self-reported and
unauditable. Participation counts for the state come from the Direct Selling Association, the
industry's trade group.

Read it for two things at once. It is the best available measurement of the cluster's real
industrial weight — 91 companies and 66 key suppliers, 16,990 payroll jobs between them (11,678 at the
companies themselves), at wages 18.4% above the average for other Utah industries, and international
sales that dwarf every other Utah export except gold. And it is, in its own
footnotes, the clearest published account of how thin the earnings of the industry's sales force
are: median annual pre-expense earnings at the reporting companies ranged from $70 to $3,000, and
at one large company fewer than a third of the people signed up as sales representatives recorded
any sales at all.

## Useful Claims

- **Industry size (2020):** 91 direct-selling companies and 66 key suppliers headquartered in Utah;
  10 surveyed companies alone reported more than $10.3 billion in global sales, which the report
  puts at 6.1% of direct-selling sales from all states and countries.
- **The concentration claim, stated precisely:** Utah consumers were 1.2% of U.S. direct-selling
  retail sales while Utah-headquartered companies supplied over 10.0% of U.S. direct selling. Utah
  is a production center for the industry far more than it is a market for it — that asymmetry, not
  per-capita consumption, is the defensible version of "direct-selling capital."
- **Employment (2020), and read the components rather than the total:** Table 1 gives 17,487 jobs as
  the sum of three unlike things — **11,678** at the 91 direct-selling companies, **5,312** at the 66
  selected suppliers, and **497** attributed to convention visitation. The first two are Utah Department
  of Workforce Services payroll aggregations, the firmest figures in the study; the 497 is REMI model
  output from estimated visitor spending, so it is not a counted payroll. A further 20,751 jobs are
  described as indirectly supported, also modelled. The employment figure is also by place of work, not
  place of residence, which the executive summary's "17,487 Utah residents" blurs.
- **Wages (2020):** $63,652 average pay per employee, 18.4% above the average for other Utah
  industries.
- **Total modelled impact (2020):** 38,238 Utah jobs and $2.7 billion in statewide earnings — 1.8% of
  Utah employment and 2.2% of residents' earnings. Only the 17,487 jobs and $1.3 billion of earnings are
  called direct; the rest is multiplier output.
- **The report gives two different tax-revenue figures and this page does not choose between them.**
  Section 1's narrative says "$182.8 million in annual state and local tax revenue"; the fiscal-impacts
  section and Table 2 give **$191.4 million**, which Table 2 splits into $127.1 million of state revenue
  and a local column reading `$64.3` in millions of dollars, against
  $46.6 million of government operating expenditures for a net $144.7 million. $182.8 million appears in
  no table. Anyone citing a tax figure should quote which one and note that the document is internally
  inconsistent here.
- **Who the large employers are (2020):** 21 Utah direct-selling companies had at least 100 in-state
  employees, founded between 1972 and 2017. The two largest employers were **doTERRA** (2,265–3,526
  Utah jobs) and **Young Living** (1,505–3,007), each above 1,500 — both larger in Utah than
  **Nu Skin** (606–1,260) and **USANA** (520–1,048), with **Nature's Sunshine** (370–797) fifth. Ranges
  rather than counts because DWS suppresses exact per-company employment. Table 5 records only company,
  jobs range, and year established; it says nothing about which firms are publicly traded, and at least
  four in it are (Nu Skin, USANA, Nature's Sunshine, LifeVantage), so do not read the top of this table
  as "the private firms outrank the public ones."
- **The founding years in Table 5 are soft, by the table's own note:** "Companies have reorganized and
  renamed themselves over the years. Some had significant precursors before the founding year given."
  Nature's Sunshine (1972) is the earliest year in the table; Nu Skin's is 1984.
- **Geographic concentration (2020):** of 114 in-state direct-selling establishments, 55% were in Utah
  County and 34% in Salt Lake County. Utah County held over 8,600 direct-selling jobs — 73.8% of the
  **11,678** jobs at direct-selling companies, which is what Figure 8 counts, not of the 17,487 total —
  against more than 2,350 in Salt Lake County and 707 in the six remaining counties.
- **Convention economy (2015–2019):** out-of-state attendees at direct-selling conventions in Utah
  spent an estimated $41.6 million a year, pre-pandemic.
- **Exports (2020):** $6.3 billion in international sales from selected Utah companies — 71.7% of
  the state's non-gold commodity exports.
- **Participation (2020):** an estimated 229,797 Utah residents were sales representatives or
  discount buyers, 9.9% of the state's adult population, versus a 6.5% national average (Direct
  Selling Association figures).
- **Sales-force earnings (2020):** at six companies reporting in-state representative income,
  15,322 representatives earned $94.8 million total — a $6,186 mean before expenses, with
  company-specific means from $574 to $10,650 and company **medians from $70 to $3,000**.
- **Why those means are not comparable:** companies differed on whether people with $0 in sales
  were counted. Removing zero-sales representatives raised the average 216% at one company and
  653% at another. Footnote 31 accounts for only five of the six reporting companies — three "provided
  averages that included individuals with $0 in 2020 sales", two are the ones whose averages the footnote
  says removal would raise, and the sixth is not explained.
- **The report points onward to the companies' own income-disclosure statements.** Footnote 32 cites four
  by name: doTERRA (2019), Young Living (2020), Nu Skin's 2020 U.S. Brand Affiliate compensation summary,
  and USANA's 2020 income disclosure — the primary documents behind any per-representative earnings
  claim, and the reason [doTERRA's current disclosure](doterra-earnings-disclosure-2026.md) is captured
  separately here.
- **How few sell anything:** at one large Utah company, "just under one-third" of its independent
  sales representatives documented any sales in 2020.

## Verbatim

> "The industry comprises 91 direct selling companies and 66 key suppliers. Ten of these direct
> selling companies with Utah headquarters provided more than $10.3 billion in goods and services
> to their customers around the world, 6.1% of industry sales from all states and countries."
> — Executive summary

> "While Utah consumers accounted for 1.2% of U.S. retail sales in the industry, Utah direct selling
> companies provided over 10.0% of direct selling nationwide."
> — Section 2

> "Economic Impacts—The direct selling industry employed 17,487 Utah residents, and industry activity
> indirectly supported another 20,751 jobs."
> — Executive summary, key findings

> "Direct Selling Companies 91 11,678 Selected Suppliers 66 5,312 Convention Visitation NA 497 Total 157 17,487"
> — Table 1, Utah Direct Selling Industry Components, 2020 (component, companies, jobs)

> "Economic modeling provides employment estimates but not"
> — Note to Table 1, on where the convention-visitation jobs come from

> "High Wages—At $63,652 per employee, direct selling companies paid their Utah employees an average
> of 18.4% more than companies in other industries in 2020."
> — Executive summary, key findings

> "Exports—International sales of $6.3 billion from selected direct selling companies in Utah made
> up 71.7% of the state's non-gold commodity exports in 2020."
> — Executive summary, key findings

> "Business Travelers—Out-of-state visitors who attended direct selling conventions in Utah spent an
> estimated $41.6 million annually from 2015 to 2019."
> — Executive summary, key findings

> "In 2020, direct selling companies generated 38,238 Utah jobs and $2.7 billion in statewide earnings
> (see Figure 1). This significant economic activity constituted 1.8% of Utah employment in all
> sectors and 2.2% of its residents' earnings. Direct impacts within the direct selling industry were
> 17,487 jobs and $1.3 billion in earnings."
> — Section 1

> "Economy-wide impacts from the spending of direct selling companies and their suppliers and workers
> included $2.7 billion in earnings, 2.2% of the state total for all residents, and $182.8 million in
> annual state and local tax revenue."
> — Section 1

> "in 2020, government entities received an estimated $191.4 million in tax revenues from the economic
> activity associated with the 38,238 jobs that the industry created or indirectly sustained (see Table
> 2)."
> — Section 3, Fiscal Impacts — the figure that contradicts Section 1's $182.8 million

> "These revenues far exceeded government expenses, estimated at $46.6 million, for services to
> residents whose jobs depended on direct selling companies. The net fiscal impact was a $144.7 million
> annual flow."
> — Section 3, Fiscal Impacts

> "An estimated 91.3% of $127.1 million in state revenue came from sales ($57.2 million) and personal
> income taxes ($58.8 million)."
> — Section 3, on the state half of the $191.4 million

> "Tax revenues $127.1 $64.3 $191.4"
> — Table 2 (category, state, local, total, millions of dollars)

> "Principal Utah employers in the direct selling industry include 21 direct selling companies with at
> least 100 employees (see Table 5). The companies were founded between 1972 and 2017." [...] "The
> largest two employers, doTERRA and Young Living, each provided more than 1,500 jobs, and the three
> companies rounding out the top five were Nu Skin, USANA Health Sciences, and Nature's Sunshine."
> — Section 2

> "doTERRA 2,265 to 3,526 2008 Young Living 1,505 to 3,007 1993 Nu Skin 606 to 1,260 1984 USANA Health
> Sciences 520 to 1,048 1992 Nature's Sunshine 370 to 797 1972"
> — Table 5, Utah's Largest Employers (company, jobs range, year established)

> "Of 114 in-state direct selling establishments operating in 2020, 55% were in Utah County, 34% were
> in Salt Lake County, and the remaining 11% were in Washington, Davis, Kane, Weber and Duchesne
> counties."
> — Section 2

> "Over 8,600 direct selling jobs were in Utah County, nearly three-fourths (73.8%) of the industry's
> statewide total (see Figure 8). Salt Lake County was home to more than 2,350 direct selling jobs, and
> the remaining 707 jobs were in Washington, Davis, Kane, Weber and Duchesne counties."
> — Section 2

> "Disclosure limitations prevent the reporting of exact employment counts for these counties. Totals
> are 11,678 jobs and $802.6 million in wages."
> — Note to Figure 8

> "an estimated 229,797 people in Utah participated in the industry as sales representatives
> (independent contractors operating their own businesses) or discount buyers (preferred customers
> who do not make sales), together 9.9% of the adult population reported by the U.S. Census Bureau"
> — Section 4

> "Utah's share was well above the national average of 6.5%, and Utah ranks ninth among all states
> and DC in this regard."
> — Section 4

> "In 2020, their 15,322 sales representatives earned a collective $94.8 million in documented
> commissions and related income. The mean of annual earnings from direct selling (before expenses)
> was $6,186 per representative, and company-specific means ranged from $574 to $10,650 per
> representative."
> — Section 4

> "company medians for their sales representatives' annual earnings ranged from $70 to $3,000 before
> expenses"
> — Section 4

> "For example, just under one-third of sales representatives who are independent contractors for a
> large Utah company documented any sales in 2020."
> — Definitions box, "Discount buyers or preferred customers"

> "Reporting varied in terms of whether companies included individuals eligible to sell with no
> income in 2020 in companies' average or median calculations. [...] Removing sales representatives
> with zero sales from the calculation increased the average by 216% for one company and 653% for
> another company. The remaining three companies that responded provided averages that included
> individuals with $0 in 2020 sales."
> — Footnote 31

> "The Utah Direct Selling Coalition and Utah Governor's Office of Economic Opportunity commissioned
> this study. The coalition is made up of 18 Utah-headquartered companies (12 direct selling
> companies and six direct selling suppliers)."
> — Acknowledgements

## Reliability Notes

**Commissioned by the industry it measures.** The Utah Direct Selling Coalition — 18
Utah-headquartered direct-selling companies and suppliers — co-commissioned the study with the
Governor's Office of Economic Opportunity, and the survey instrument was administered by Dorsey &
Whitney LLP, which represents companies in the sector. The Gardner Institute discloses all of this
in its acknowledgements and methods, which is why the study is usable at all; it is also why the
page is `Confidence: Medium` and typed `reference` rather than `dataset`. Cite it for magnitudes and
for its own disclosed limitations, not as an independent audit.

**Which numbers are auditable and which are not.** Employment at the companies and their suppliers
(11,678 and 5,312), the wage figure ($63,652), and the industry-count work rest on Utah Department of
Workforce Services administrative aggregations and a supplier list built by Dorsey & Whitney from expert nomination. Sales
($10.3 billion), export share (71.7%), in-state representative counts (21,457), and every earnings
figure come from a 12-company survey with 10 respondents, de-identified before the researchers
received it — so no third party, including the authors, can check a respondent's arithmetic. The
report says so; a page citing the $10.3 billion should say so too.

**The earnings figures are the report's most-quoted and most-fragile numbers.** Footnote 31 records
that companies did not use a common denominator: some included people with $0 in sales, some did
not, and dropping the zero-sellers raised one company's average by 653%. That single footnote means
the $6,186 mean cannot be read as "what a Utah direct seller earns," and it also means the range of
medians ($70 to $3,000) is a lower bound on how thin the bottom of the distribution is, not a
distortion of it.

**Indirect-jobs figures are model output — and so is part of the "direct" total.** The 20,751
indirectly supported jobs come from input-output multipliers, not counted payrolls, as do the headline
38,238 jobs and both tax-revenue figures. Less obviously, 497 of the 17,487 *direct* jobs are also
modelled: they are the employment REMI PI+ attributes to out-of-state convention visitors' spending, and
the report is explicit that "economic modeling provides employment estimates but not company counts."
The measured payroll figure is 16,990, or 11,678 if you want only the direct-selling companies
themselves. An earlier version of this page called 17,487 "the study's firmest number", which mixed a
model estimate into an administrative count.

**The county figures rest on a narrower base than the headline, and not because of suppression.** Utah
County's 8,600-plus jobs are "nearly three-fourths (73.8%)" of 11,678 — the total for direct-selling
companies, which is what Figure 8 counts, as its title ("Direct Selling **Company** Employment and Wages
by County") says. The gap to 17,487 is the 5,312 supplier jobs and 497 convention jobs, not missing data.
DWS disclosure rules do bite here, but only on the six small counties whose 707 jobs the report cannot
break out individually. Quoting "73.8% of direct-selling jobs are in Utah County" without naming the base
overstates the claim, though the concentration itself is not in doubt — 55% of establishments are in Utah
County as well.

**Capture detail.** `gardner.utah.edu` serves the PDF through its own CDN, so the fetch redirected
to `d36oiwf74r1rap.cloudfront.net` at the identical `/wp-content/uploads/DirectSales-Aug2022.pdf`
path — a WordPress asset-offload for the Institute's own file, not a different publisher. The
captured text is extracted from that 24-page PDF, so hyphenated line breaks in the original appear
as such in the raw file; quotes above avoid spans that cross them.

**2020 data, published 2022.** Every figure describes calendar 2020 — a pandemic year that was
unusually good for direct selling nationally. Later years are not covered here; for current company
scale use the SEC filings ([USANA FY2025](usana-10k-fy2025.md), [Nu
Skin FY2025](nu-skin-10k-fy2025.md)), which show sharp declines from the 2020 peak.

## Related Pages

- [Utah's Direct-Selling Industry](utah-direct-selling-industry.md)
- [USANA Health Sciences FY2025 Form 10-K](usana-10k-fy2025.md)
- [Nu Skin Enterprises FY2025 Form 10-K](nu-skin-10k-fy2025.md)
- [doTERRA Opportunity and Earnings Disclosure](doterra-earnings-disclosure-2026.md)