What FTC rules apply to supplement influencer marketing?

Three FTC sources matter most. The Guides Concerning the Use of Endorsements and Testimonials in Advertising (revised in 2023) set disclosure and honesty rules. The Health Products Compliance Guidance (December 2022) sets the evidence standard for health claims. The Trade Regulation Rule on the Use of Consumer Reviews and Testimonials took effect in October 2024.

The Endorsement Guides are published at 16 CFR Part 255. They are guidance on how the FTC applies its law against deceptive advertising, so breaking them can lead to an enforcement action. The 2024 review rule is a binding rule, which allows the FTC to seek civil penalties for violations. FDA rules on supplement labeling and structure/function claims also apply to what a creator says, because creator content is part of your marketing. For a plain-English definition, see our FTC Endorsement Guides glossary entry.

The disclosure must be difficult to miss and easy to understand. Put it in the post or video itself, not only in a profile bio or behind a "more" link. Use plain words such as "ad", "sponsored" or "I was paid by". In video, say it out loud and show it on screen.

• Placement: at the start of a caption, not buried among hashtags at the end.
• Video and live streams: in the audio and on screen, repeated during long streams.
• Short-form video: on screen long enough to read, not only in the caption.
• Platform tools: a built-in "paid partnership" label may help, but the FTC says it may not be enough on its own.
• Language: the disclosure should be in the same language as the endorsement.

The FTC's Disclosures 101 for Social Media Influencers gives plain examples you can attach to every creator brief.

Expert endorsers carry a higher bar. Under the Endorsement Guides, a person presented as an expert must actually have the expertise implied. Their endorsement must also come from a real evaluation of the product using that expertise. A title, white coat or "Dr." in a handle signals expertise, so the rules apply.

What this means in practice

• Check credentials before signing. A registered dietitian, pharmacist or physician should hold the license or credential the content implies.
• Give the expert the formula, the evidence file and the label, and let them decide what they can honestly say.
• Do not script an expert to approve claims they have not reviewed.
• Disclose the payment or advisory relationship in every post, just as for any creator.
• Respect professional rules. Licensed clinicians and dietitians answer to state boards and professional codes that may limit product promotion.

An expert endorsement also does not lower the evidence standard for the claim itself. If the brand lacks competent and reliable scientific evidence for a benefit, a clinician repeating the benefit does not fix that. Treat expert content as a way to explain lawful claims clearly, not as a way to stretch them.

Start with an approved-claims sheet drawn from your substantiation file, then build creator selection, contracts, briefs and monitoring around it. Pick creators whose audience fits your product and who are willing to follow a disclosure standard. A smaller program run carefully beats a large one nobody checks.

Practical steps that help most brands:

• Prefer creators who actually use the product category and can speak about it honestly.
• Pay a clear fee rather than relying only on performance commission, so expectations are simple to disclose.
• Give dietitians or clinicians separate briefs that respect their professional standards.
• Reuse creator content in ads only after rechecking claims and disclosure.

We run creator programs as part of our supplement and D2C health brand marketing work, with the claims sheet built first. If you want your current creator posts reviewed against these rules, book a call with the US team.