FTC Expectations for Social Media Influencers
What is the FTC?
The Federal Trade Commission (FTC) is responsible for protecting American consumers by promoting competition and forbidding deceptive and unfair business practices. The FTC accomplishes this through “enforcement, advocacy, and education.”
FTC Disclosure Guidelines for Influencers
In order to endorse a product with the utmost honesty, the FTC expects influencers to follow certain guidelines when posting sponsored content. It’s important to note that it’s your responsibility as an influencer to make disclosures about working with brands to advocate for a product.
According to an NPR article written in 2019, “Many consumers rely upon influencer recommendations in making purchasing decisions, and they should know when a brand paid an influencer for an endorsement, because it affects the weight and credibility the consumers may give to that endorsement,” Michael Atleson, a staff attorney for the FTC’s Bureau of Consumer Protection, said.
In other words, influencers must be transparent with their audience by preventing the release of deceptive or misleading ads.
When Should I Disclose?
The FTC requires that influencers make a disclosure when they have a financial, employment, personal or family relationship with a brand.
*Note: financial relationships aren’t limited to money; they include receiving a free or discounted product from the brand or other perks.
How Do I Disclose?
It’s important that your disclosures are outwardly visible and easily understandable. The disclosure should be placed alongside the specific endorsement message, as opposed to on your profile page, in a list of hashtags, or in any other location that requires a person to click “more.”
Specifically, for photos on Snapchat or Instagram Stories, the disclosure should be evidently visible on top of the image. For videos, the disclosure should appear in the actual video, as opposed to in the description. For live streams, the disclosure should appear at multiple points in time so that new viewers (who join the live stream in the middle of it) will also be exposed to it.
To ensure that your disclosures are easily digestible, it’s important to use clear and obvious wording. For example, you should include words or phrases in your posts, such as:
“Advertisement”
“Ad”
“Sponsored”
“Thank you to [insert brand name] for [insert product name]”
To avoid confusion, the FTC advises that the disclosure is written in the same language as the endorsement. The FTC also prohibits influencers from promoting products they haven’t actually tried or promoting products in a positive light that they didn’t genuinely enjoy. We can’t stress enough the significance of authenticity and transparency in the influencer marketing industry.
Foodie Tribe Requirements for Sponsored Content
When you’ve been selected for a campaign at Foodie Tribe, we will always make sure to send you an influencer agreement, which includes a detailed campaign content checklist. This will help you to remember to include the required information in your content prior to submitting it for approval.
The checklist includes, but is not limited to, the following:
You have referenced your Campaign Details and Campaign Creative Brief provided by the Foodie Tribe Team and your content includes all of the required materials for your campaign.
The product or brand sponsoring your content is clearly featured and identifiable. If applicable, any product packaging is also featured prominently and clearly in your content.
For recipe content, the product / brand is clearly featured in the hero image. If it is an ingredient in the dish, make sure to include prep imagery that prominently features the product / brand in addition to imagery of the final completed recipe.
Edits are subtle and do not alter the colors or appearance of the product, packaging, or brand.
Your images are sharp, with the object clearly in focus. Lighting is used appropriately, meaning the images are neither too dark nor too overexposed.
You use correct grammar and punctuation in your content copy and captions.
You have used the brand / product name correctly throughout your content. Triple check that any brand @mentions and handles are properly spelled when posting content!
Your captions include #ad or #sponsored.
Relevant campaign hashtags, tags, and mentions are included on every piece of content and every Story, unless otherwise noted by Foodie Tribe.
As an influencer, it’s crucial that you abide by the FTC guidelines when posting sponsored content. Ensuring that your posts are genuine and truthful will contribute to a more dedicated and engaged community of followers.