A glowing customer quote on a product page feels like the customer's words, not yours. The FTC sees it differently: once you feature a testimonial in your marketing, you are responsible for what it says. This guide covers what that means in practice. This is general information, not legal advice.
Featuring a testimonial makes it your claim
The FTC's guidance on its Consumer Reviews and Testimonials Rule says a business that places testimonials on its own website is disseminating them, not merely hosting them. The rule went into effect on October 21, 2024, and it authorizes courts to impose civil penalties for knowing violations.
- Fake or false testimonials: If testimonials you feature are fake or false, the business could be liable
- Your marketers: The FTC's endorsement guidance says your company is ultimately responsible for what others do on your behalf
The claim still needs proof
An honest testimonial is not evidence that a product works. The FTC's Health Products Compliance Guidance says it is not enough that a testimonial represents the honest opinion or experience of an endorser. You also need appropriate scientific evidence for the underlying claim.
| Example testimonial (illustrative) | What it implies |
|---|---|
| "My knee pain was gone in a week" | The product relieves knee pain |
| "I lost 20 pounds in a month" | Users can expect similar weight loss |
If you could not make the claim yourself, you cannot make it by quoting a customer.
"Results not typical" does not fix it
The same guidance says testimonials reporting results more dramatic than users can generally expect are likely to be deceptive. A small disclaimer does not solve that.
- ❌ A dramatic result with "Results not typical" underneath. The FTC says this does not cure the deception
- ✅ A clear and conspicuous disclosure of the results a typical customer can actually expect
- ✅ Testimonials that reflect an ordinary experience
Disclose connections
If the person giving the testimonial was paid or given something of value, such as a free product, the FTC says that connection should be disclosed clearly and conspicuously. The same goes for people close to the business.
- Free product or payment: Disclose it next to the testimonial
- Employees and insiders: Must clearly and conspicuously disclose their relationship to the business
- Friends and relatives: Should say they are a relative or friend
How you collect reviews matters too
The rules also cover how reviews are gathered and displayed, not only what they say.
- ❌ Offering a discount or other incentive on the condition that the review is positive
- ❌ Asking for reviews only from customers you expect to be happy, which the FTC says would be misleading
- ❌ Suppressing negative reviews
- ✅ Asking every customer, and showing what they say
For the claim rules themselves, see supplement claims under the FDA and FTC.
Doing this at scale
ContentGuard scans your product descriptions and classifies each claim as safe, risky or prohibited against the rule profile you choose, including Generic FTC. It cites the governing FDA or FTC rule, scores each page, and proposes a rewrite you can apply in one click. It is a screening tool, not a substitute for legal review. See ContentGuard.