What FTC rules apply to supplement customer reviews and ratings?

Four federal sources do most of the work. The Consumer Reviews and Testimonials Rule, in effect since October 2024. The Endorsement Guides, revised in 2023. The Consumer Review Fairness Act of 2016. And Section 5 of the FTC Act, which the FTC's Health Products Compliance Guidance applies to supplement claims, including claims made through testimonials.

The rule matters most because it changed the stakes. The Endorsement Guides are guidance. Part 465 is a trade regulation rule, so knowing violations can lead to civil penalties rather than only an order to stop. It was published in the Federal Register in August 2024.

The rule reaches further than a brand's own store. "Consumer review" covers star ratings with no text at all, on any site or platform built in whole or part to collect reviews. That includes marketplaces, retailer sites and map listings. "Testimonial" covers advertising messages that buyers would read as a real customer's experience, including video and social posts. Some provisions, such as the ban on review suppression by threats and on fake social indicators, apply to "anyone," not only the selling business. That pulls in the reputation and growth vendors a brand hires, which is another reason to put these rules in writing in every marketing contract.

Platform rules sit on top. Marketplaces and app stores set their own review policies, often stricter than federal law. Check each platform's current policy. State consumer protection laws can also apply, so confirm the full picture with counsel.

Yes, with limits. An incentive can never depend on a positive review, which Part 465 bans outright. A neutral incentive offered for any honest review is allowed under federal guidance if the review discloses it. Free product counts as a material connection. Many platforms ban incentivized reviews entirely, so their rules may decide.

The FTC's guide to soliciting and paying for reviews, published in January 2022, sets out the practical lines. Do not ask only customers you expect to be happy. Do not ask people who have not used the product. Staff, friends and family who review must disclose their connection. If you offer something for a review, make it available whatever the rating, and make sure the review discloses it.

What counts as a material connection

Section 255.5 of the Endorsement Guides lists payment, free or discounted products, early access, and the chance to win a prize as examples. A disclosure must tell readers the nature of the connection clearly enough to weigh it. "Received free product from the brand" works. A buried hashtag or a link-only disclosure does not meet Part 465's definition of clear and conspicuous, which says an online disclosure must be unavoidable and is not clear if a consumer must click a link or hover over an icon to see it.

Our glossary explains review gating in more detail.

Because once a brand features a review, the review's claims become the brand's claims. The Endorsement Guides say consumer endorsements about performance must be substantiated as if the brand said it directly, and that they are not themselves competent and reliable evidence. A real buyer saying a product cured a disease is still a disease claim when you repost it.

Section 255.2(a) is explicit on substantiation. Section 255.2(b) adds typicality. A testimonial about a key attribute implies most users get similar results. If you cannot show that, you must clearly disclose what people generally can expect, and the disclosure must actually change the overall impression. The FTC's guidance gives an example: a page made entirely of dramatic testimonials with a disclaimer that results are not typical is still likely to be deceptive.

A safe rule for featured reviews

1. Feature reviews that speak to taste, ease of use, packaging, delivery and service.
2. Feature performance reviews only when the benefit is an approved claim with evidence on file.
3. Never feature or quote reviews that mention a disease, a medication or stopping a medication.
4. Keep featured reviews out of paid ads unless they pass the same claims review as the ad itself.

The organic review stream is different from what you choose to amplify. You generally should not delete honest reviews for mentioning a condition, but you should not promote them. Our guide to FTC and FDA supplement advertising rules explains the disease-claim line in full.

A compliant program asks every buyer for an honest review the same way, never conditions incentives on sentiment, publishes all genuine reviews under a written moderation policy, labels connected reviewers, and keeps disease testimonials out of marketing. It is documented, so you can show regulators what you did and why.

Monthly routine

1. Confirm the review request flow goes to all buyers, not a filtered group.
2. Sample moderation decisions against the written criteria.
3. Check that incentivized and connected reviews are labeled.
4. Review featured reviews and ad testimonials against the claims list.
5. Scan ambassador and affiliate posts for missing disclosures and disease claims.
6. Log any legal threats or takedown requests and route them to counsel.

Ichelon Consulting US sets up review request flows, moderation policies and testimonial reviews for supplement and D2C health brands. We do not give legal advice; counsel makes the legal calls. Across ICG, we have worked only in healthcare since 2018. US retainers start from $499/month, custom-scoped. See our supplement and D2C health brand marketing service, or book a call to review your current program.