The FTC’s revised Guides emphasize a focus on social media and in particular the relationship between advertisers and the products being advertised;
“The issue is – and always has been – whether the audience understands the reviewer’s relationship to the company whose products are being reviewed. If the audience gets the relationship, a disclosure isn’t needed.”
The FTC Guides retain a core purpose of protecting consumers from misleading or inaccurate advertisements and while the connection between Subway and Jared may have been readily apparent, “on a personal blog, a social networking page, or in similar media, the reader may not expect the reviewer to have a relationship with the company whose products are mentioned. Disclosure of that relationship helps readers decide how much weight to give the review.”
The FTC recently addressed consumers’ questions regarding its newly adopted Revised Endorsement Guides on its FAQ’s page. This FAQ page can be found here.