Keeping Your Content Compliant with FTC Endorsement Guidelines

  • Last update: Updated

IMPORTANT NOTE: The materials in this article are for informational purposes only and do not constitute legal advice. Be sure to contact your own legal counsel if you have questions or concerns about compliance

Howl is the place that honors honest reviews. That means a few different things:

  1. Your reviews must be truthful and reflect your honest opinions and actual experience with the products you’re reviewing;
  2. Your depiction of the products in photographs or video must accurately demonstrate the products’ qualities and performance: do not use any special effects or any other methods to enhance or alter the performance or appearance of the product;
  3. You must clearly and conspicuously disclose your relationship with the merchants whose products you’re reviewing. It is important that your followers understand that you’re earning commissions when they purchase products with the merchant links in your content.

Following these rules is not only required by Federal Trade Commission (FTC), the government agency that monitors social media and enforces truth-in-advertising requirements, but it also builds trust with your audience.

As a creator on Howl, you are required to comply with the FTC’s Endorsement Guidelines (links to which are included below) every single time you post your links. It’s your responsibility to remain honest and truthful to your audiences.

With respect to disclosing your relationship with the merchants, such disclosures must be clear, conspicuous, and accurately describe your relationship with the merchant.

  1. Clear:
    1. Your disclosure needs to be clear in communicating that you may earn from your links. Consider using a simple statement like “I earn a commission if you click on this link and make a purchase from the merchant.”
    2. You may also use the hashtag “#[Merchant]Partner + #Affiliate” though please use the plain English disclosure too whenever possible.
    3. Do not use jargon, vague, or confusing terms like “collab,” “ambassador,” or “spon” that consumers may not understand
  2. Conspicuous:
    1. The disclosure needs to be placed near your link or endorsement in a place that is hard to miss.

What’s deemed clear and conspicuous will vary by the medium where the endorsement is made.

  • Video: Given the audio and visual components of video, disclosures should be made in audio, video, and at the top of the video description.
  • Livestream: The disclosure should be repeated periodically so viewers who only see part of the stream will get the disclosure.
  • Picture: Superimpose the disclosure over the picture and make sure viewers have enough time to notice and read it.
  • Website: Disclosures should be made at the top of the page, not just in an “about me” page and the notice should not require a person to click a link to learn more.
  • Space-limited platforms: Use clear hashtags that indicate a material connection with merchant partners, such as “#[Merchant]Partner + #Affiliate”

The cases of FTC complaints against creators are on the rise. Your compliance is critical to your business. It’s your responsibility to keep up to date with the most recent guidelines, as they will change from time to time. The FTC has a number of resources available, including the following articles on guidance:

The FTC's Endorsement Guides: What People Are Asking

Disclosures 101 for Social Media Influencers (PDF)