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NAD Disclosure Requirements

Kelley Drye & Warren LLP

Multiple Bites at the Apple over AI Claims

When Apple announced the iPhone 16 last year, it advertised that it would be ​“the first iPhone built for Apple Intelligence.” Apple touted several AI features and advertised that Apple Intelligence is ​“Available Now.” In...more

Kelley Drye & Warren LLP

NAD Decision Addresses Review Claims

Yesterday, we posted about a decision in which P&G challenged claims that Rascals made about the absorption capabilities of its diapers. Rascals also advertised: ​“210,000+ 5-star reviews of Rascals Products.” P&G thought...more

BakerHostetler

Don’t Skim(p) on Disclosures

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And we’re back with more NAD drama! You may remember that earlier this year, we blogged about a case where the National Advertising Division (NAD) of the Better Business Bureau found that disclosures @Revolve and the...more

Kilpatrick

NAD Finds Kevin Hart’s Social Media Disclosures Insufficient in Monitoring Decisions

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Kevin Hart may know how to land a punchline, but the National Advertising Division (“NAD”) recently reminded him that when it comes to influencer endorsements, the only thing that should be subtle is the humor—not the...more

Dorsey & Whitney LLP

Tips on How to Shape Up Your Influencer Advertising Program: The NAD Reviews Skims’ Instagram Posts for Proper Disclosures

Dorsey & Whitney LLP on

For years now we’ve been blogging about how much the FTC and even the SEC on occasion love scrolling Instagram posts to see what influencer are up to. This post is about another three letter organization who likes to scroll...more

BakerHostetler

[Podcast] AD Nauseam: The Safety Dance on Safety Claims

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In this episode, the discussion revolves around safety claims and risk reduction in advertising, with a focus on FTC and NAD regulations. The hosts, Amy Mudge and Daniel Kaufman, highlight several key cases, including...more

Kelley Drye & Warren LLP

NAD Reviews More Influencer Posts

As part of its on-going monitoring of influencer campaigns, NAD recently launched an inquiry to assess whether influencers Brittany Mahomes and Lana Del Rey had adequately disclosed their relationship to Skims Body – a...more

Kelley Drye & Warren LLP

NARB Offers Guidance on Product Demonstrations

James Hardie Building Products makes fiber cement home siding. The company produced a video demonstration that compared the combustibility of its siding to various competing products when exposed to a blowtorch. At the...more

Kilpatrick

Are Your Ads Sending the Wrong Message? Lessons from Total Wireless

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The National Advertising Division (“NAD”) recently took Total Wireless, a prepaid brand under Verizon, to task for a TV commercial that blurred the lines between two separate offers, leaving consumers potentially confused....more

Kelley Drye & Warren LLP

NAD Considers Whether ​“Number 1” Claims Can be Qualified

DREO advertises that it is the ​“No. 1 Fan and Heater Brand” in the United States. Lasko, a competitor, thinks that it is, in fact, the ​“number 1” brand in both of those categories. Because there can’t be two ​“number 1”...more

Venable LLP

National Advertising Division Targets Celebrity, Influencer, and Third-Party Marketing in Recent Decisions

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The National Advertising Division (NAD) recently issued a series of decisions addressing influencer and third-party marketing. The NAD is a self-regulatory body that assesses the truth and accuracy of claims made in national...more

Kelley Drye & Warren LLP

NAD Holds Celebrity Social Media Posts Need Disclosures

Under the FTC’s Endorsement Guides, influencers and celebrities have to disclose any material connection they have to the brands they promote ​“when a significant minority of the audience for an endorsement does not...more

ArentFox Schiff

NAD Monitoring Program Results in Decision on Influencer Marketing

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In a recent decision, the Better Business Bureau’s National Programs’ National Advertising Division (NAD) took issue with social media content posted by influencers engaged by Revolve Group, Inc. and recommended that the...more

Kelley Drye & Warren LLP

NAD Decision Addresses Gifting to Influencers

Revolve is an e-commerce fashion brand that relies heavily on influencers to promote its products. Some of those influencers promote the products pursuant to agreements with the company, while others promote the products as...more

BakerHostetler

NAD Keeps It Real: Recommends Modification of Reality TV Ambassadors’ Posts to Clearly Disclose Material Connection to Clothing...

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The National Advertising Division (NAD) of the Better Business Bureau is just like us! They seem to watch “Love Island” and maybe even “Too Hot to Handle” (#blushing) if the latest news is any indicator....more

Davis Wright Tremaine LLP

Stay ADvised: 2025, Issue 3

FTC's Final Junk Fees Rule Narrowed in Scope - On December 17, 2024, the Federal Trade Commission (FTC) released its final Rule on Unfair or Deceptive Fees, commonly known as the "Junk Fees Rule." This final rule has a...more

Kelley Drye & Warren LLP

NAD Decision Addresses Content Creators on TikTok

TikTok offers an affiliate program through which influencers and other content creators can earn commissions by promoting products from various brands through affiliate links in their videos. Marketing experts often caution...more

BakerHostetler

NAD’s SWIFT Disclosure Track Commands Respect at a Bargain

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NAD has amended its SWIFT track processes and procedures multiple times since its inception in an effort to make sure the process is fair yet efficient. While it met with some nontrivial resistance from industry at its...more

Kelley Drye & Warren LLP

NAD Addresses Influencer Disclosures in Challenge Between Competitors

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This week, NAD announced a decision in a dispute between Mielle Organics and Kreyol Essence – two competitors in the beauty and personal care market – that focused on whether an influencer had clearly disclosed her...more

Kelley Drye & Warren LLP

NAD Recommends More Prominent Disclosures on Beauty Influencer Posts

Last year, the FTC updated its Endorsement Guides to impose more stringent requirements on how influencers must disclose their relationships to the companies whose products they promote. Although the FTC later sent letters to...more

BakerHostetler

NAD Conference Recap: Who’s Your Sponsor?

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The topic of material disclosures was a running theme at this year’s NAD Conference. Following the one-year anniversary of the FTC’s updates to the Endorsement Guides (Guides), NAD staff shared how they were applying and...more

Kelley Drye & Warren LLP

NAD Decision Considers “As Seen In” Claims

LegalZoom has a box on its website with the title ​“As Seen In” followed by the logos of five publications that have featured its services. In an NAD challenge, ZenBusiness argued that because LegalZoom has an affiliate...more

Shook, Hardy & Bacon L.L.P.

NAD Finds Fenty Skin Cleanser Claims Supported, Recommends Changes for Influencer Disclosures

The Better Business Bureau’s National Advertising Division (NAD) has ruled that Fenty Skin LLC provided a reasonable basis for certain product claims made during product demonstrations on social media featuring influencers...more

Kelley Drye & Warren LLP

NARB Disagrees with NAD on Package Disclosures

Glad advertises that its ForceFlex MaxStrength bags are ​“25% more durable.” More durable than what? If you follow an asterisk, you’ll learn that they are 25% more durable than Glad’s own 13-gallon ForceFlex bags. A...more

Davis Wright Tremaine LLP

Stay ADvised: 2024, Issue 10

NAD Melts Away Fenty's Jelly Oil Endorsements, Finding Them Insufficiently Conspicuous - In a self-monitoring challenge to skincare brand Fenty and its marketing for its Melt AWF Jelly Oil Makeup-Melting Cleanser, NAD...more

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