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FTC Claim Checker — Substantiation Before Dissemination
The FTC’s standard is simple to state and unforgiving in practice: advertisers must have a reasonable basis — typically competent and reliable scientific evidence, when the claim is about health — for every objective claim BEFORE it is disseminated. There is no "we’ll get the study later". Paste your copy and this checker flags the claim patterns that carry substantiation duties under FTC rules: health and treatment outcomes, regulator endorsements, endorsement-guide violations, green claims under the Green Guides, ranking claims and "100% effective" promises. Each finding states what evidence the FTC standard expects.
What this checker inspects
- Health and treatment outcome claims: cure, treat, heal, prevent — the FTC expects competent and reliable scientific evidence for health claims
- Quantified outcome promises: "lose 15 pounds in 2 weeks" is the FTC’s textbook unsubstantiated weight-loss claim
- Regulator endorsements: "FDA-approved", "clinically proven", "doctor recommended" — the endorsement must exist before you say it
- Review and rating assertions under the fake-review rule (16 CFR Part 465) and endorsement guides (16 CFR Part 255)
- Green claims the FTC Green Guides require qualifying: eco-friendly, biodegradable, carbon neutral
- Absolute guarantees: "100% effective", "risk-free", "guaranteed results"
What it cannot do
- Whether your evidence meets the "competent and reliable" bar — that depends on the study, and only a qualified reviewer can judge it
- Sector-specific rules beyond these patterns (financial products, children’s advertising, made-in-USA and others have their own requirements)
- Legal advice — this scan is a drafting aid
Examples: flagged copy and safer rewrites
“Clinically proven to reduce joint pain in 7 days. Doctor recommended.”
Why it is risky: A health outcome claim plus a professional endorsement: the FTC standard expects the actual clinical evidence and the named endorsement to exist before dissemination.
Safer direction: Remove the clinical claim, or hold the trial data and endorsement records on file — and be able to produce them on FTC request.
“Lose 15 pounds in 2 weeks, guaranteed — risk-free!”
Why it is risky: A quantified weight-loss outcome with a guarantee is the classic unsubstantiated claim pattern the FTC’s advertising FAQ warns small businesses about.
Safer direction: Delete the number, timeframe and guarantee; describe the product, not a promised body outcome.
“Rated 5 stars by 25,000 customers. As seen on TV.”
Why it is risky: Review-count claims must be real and current under 16 CFR Part 465; "as seen on TV" implies an endorsement it cannot document.
Safer direction: Use only review counts you can link to live, dated sources.
Frequently asked questions
- What does the FTC require before I publish a claim?
- A reasonable basis for the claim before it is disseminated. For objective health claims, the FTC’s substantiation policy statement and case history mean competent and reliable scientific evidence. "Before" is the operative word — creating evidence after publication does not cure a deceptive claim.
- Are "puffery" claims exempt?
- Vague superlatives that no reasonable consumer relies on ("amazing", "incredible") can be puffery. But specific, measurable claims — "#1", "clinically proven", "kills 99.9% of bacteria" — are objective claims that require substantiation. This checker flags the objective kind.
- Do the FTC rules apply to my Amazon listing?
- Yes. The FTC Act covers advertising across channels — listings, ads, emails and social posts alike. Marketplace rules are an additional layer on top, not a substitute.
- Is this checker affiliated with the FTC?
- No. It is an independent drafting aid built on patterns drawn from FTC public guidance, linked below. It gives no legal advice and no guarantee of any enforcement outcome.
Limitations
- The checker flags claim patterns; it does not evaluate your evidence or your industry’s specific rules.
- FTC guidance evolves — decisions and rules listed here have effective dates you should verify on ftc.gov.
- A clean scan is not an FTC compliance opinion.
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