Rhinehart StudioGuide · United States
FTC rules for influencer ads, reviews and “Made in USA” claims
If you pay creators, use affiliate links, show reviews or say "Made in USA", these are the FTC rules to know, in plain English.
By Rhinehart Studio · Checked against official sources on 25 October 2026 · General information, not legal advice. For advice on your own situation, talk to a US-licensed attorney.
Endorsements and influencers
The FTC's Endorsement Guides (16 CFR Part 255, revised in 2023) say that a "material connection" between an endorser and a brand, such as payment, free products or a family link, must be disclosed clearly and conspicuously (eCFR 16 CFR 255). The FTC's plain-English guide for creators says disclosures should be hard to miss, in simple language such as "ad" or "sponsored", and placed in the video itself for video content, not only in the description (FTC: Disclosures 101; FTC FAQs).
Fake reviews and testimonials
The FTC's Consumer Reviews and Testimonials Rule (16 CFR Part 465) took effect on 21 October 2024. It bans fake reviews and testimonials, including AI-generated ones that misrepresent who wrote them, buying positive or negative reviews, undisclosed insider reviews, review suppression, and fake social-media indicators such as bought followers (eCFR 16 CFR 465; FTC Q&A). Unlike the Guides, the Rule allows the FTC to seek civil penalties.
AI-generated ads
Ads made with AI are still ads: claims must be truthful and substantiated, and an AI "customer" must not be presented as a real customer giving a testimonial. We label our AI ads as AI-generated and never imitate real people.
"Made in USA"
An unqualified "Made in USA" claim means "all or virtually all" of the product is made in the US. The FTC's Made in USA Labeling Rule (16 CFR Part 323) applies to labels and to mail-order and online promotions (FTC: Complying with the Made in USA standard). Print-on-demand products made from imported blanks generally can't carry an unqualified claim.
Quick checklist
- Paid, gifted and affiliate posts carry a clear "Ad" or "Sponsored" label
- Video endorsements disclose in the video, not only in the caption
- Every review on your site is from a real customer
- You never offer incentives for positive reviews only
- AI-generated people are never presented as real customers
- "Made in USA" is only used where all or virtually all of the product is
- Claims in ads can be backed up with evidence
FAQ
Is #ad enough?
The FTC says simple, clear words like “ad” or “sponsored” work if they are hard to miss. Hiding them among many hashtags or behind “more” does not.
Do the rules apply to small brands?
Yes. The FTC Act applies to businesses of all sizes, and to the brand as well as the creator.
Can I use AI to write reviews?
Not reviews that pretend to be from real customers. The 2024 Rule specifically covers fake reviews, including AI-generated ones.
Official sources
- eCFR: 16 CFR Part 255 (Endorsement Guides)
- FTC: Disclosures 101 for Social Media Influencers
- FTC: Endorsement Guides FAQs
- eCFR: 16 CFR Part 465 (Consumer Reviews and Testimonials)
- FTC: Consumer Reviews and Testimonials Rule Q&A
- FTC: Complying with the Made in USA standard
Laws and guidance change. Check the sources above for the latest position. General information, not legal advice. For advice on your own situation, talk to a US-licensed attorney.