All endorsements must reflect the honest experience or opinion of the endorser. Endorsements may not contain representations that would be deceptive, or could not be substantiated, if the advertiser made them directly.
Endorsements by consumers must reflect the typical experience of consumers who use the product, not the experience of just a few satisfied customers. If an endorsement doesn’t reflect users’ typical experience, the ad must clearly disclose either what consumers can expect their results to be or the limited applicability of the endorser’s experience. Saying “Not all consumers will get these results” or “Your results may vary” is not enough.
Endorsements by celebrities must reflect the celebrity’s honest experience or opinion. If the endorsement represents that the celebrity uses the product, that celebrity actually must use the product. Once a celebrity (or expert) has endorsed a product, the advertiser has an obligation to make sure the endorsement continues to reflect the endorser’s opinion.
To give an expert endorsement, a person must have sufficient qualifications to be considered an expert in the field. But just being an expert isn’t enough. Expert endorsements must be supported by an actual evaluation, examination, or testing of the product that other experts in the field normally would conduct to support the conclusions in the endorsement.
Advertisers also must disclose any material connection between a person endorsing a product and the company selling the product. A “material connection” is defined as a relationship that might affect the weight or credibility of the endorsement. For example, if an endorser is an employee or relative of the advertiser, that fact must be disclosed because it is relevant to how much weight a consumer would give to the endorsement. Similarly, an advertiser must disclose if a consumer has been paid for giving an endorsement.