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What claims can a UGC ad make?
Only claims the brand can substantiate, usually what the label or product page already supports. Word results as personal experience rather than guarantees, avoid "treat, cure or prevent" language for supplements and cosmetics, don't invent credentials like "as a nurse", and keep before-and-after content honest and typical.
The basic rule
An endorsement can't make a claim the brand itself couldn't legally make, and it must reflect the endorser's honest opinion (FTC endorsement guidance). In practice, if the label or product page can't back it up, the ad shouldn't say it.
Safer vs riskier wording
| Riskier | Safer |
|---|---|
| "Cures bloating" | "Part of my afternoon routine" |
| "Regrows hair" | "Three drops at night, quick massage" |
| "As a nurse, I recommend…" (if untrue) | No credentials unless real and relevant |
| "Lost 20 lbs in a month" | Results only if typical, or with the generally expected results stated |
| "Clinically proven" | Only if you hold the study and it says that |
Categories that need extra care
- Supplements and cosmetics: avoid treat, cure or prevent language.
- Weight loss and fitness: exceptional results need context, per the FTC guidance.
- Before and after: must be genuine and representative.
Fake testimonials are banned
The FTC's 2024 final rule bans fake reviews and testimonials, including ones that misrepresent who gave them. That applies to actors and AI presenters posing as customers.
General information, not legal advice.
Our own rules at ScrollStop Labs: AI presenters never pose as real customers, claims come from the label, and AI labels stay on.
Sources
- FTC: FTC's Endorsement Guides, What People Are Asking
- FTC: Final rule banning fake reviews and testimonials (Aug 14 2024)