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FTC Warns Manufacturers and Retailers About Made in USA Claims

As we noted earlier this month, FTC Chairman Andrew Ferguson designated July as ​“Made in USA” Month. Because Hallmark still hasn’t printed greeting cards to commemorate the month, the FTC celebrated by sending warning...more

FTC (and NAD) Celebrate ​“Made in USA” Month

On July 1, 2025, FTC Chairman Andrew Ferguson designated July as ​“Made in USA” Month. Chairman Ferguson noted that in a recent poll, 61% of Americans stated that whether a product was ​“Made in USA” played a factor in their...more

Can Companies Use ​“Mass Balance Accounting” to Substantiate Green Claims?

The International Bottled Water Association (or ​“IBWA”) challenged over 50 express and implied claims by Boxed Water is Better (or ​“BWIB”), suggesting that boxed water is better for the environment. NAD’s decision covers a...more

[Webinar] Navigating the Maze of Influencer Marketing - June 4th, 1:00 pm - 1:30 pm EST

Join Kelley Drye for a fast-paced, practical webinar, “Navigating the Maze of Influencer Marketing.” This 30-minute session will cover what companies need to know to stay compliant with evolving FTC guidance, class action...more

Two New Lawsuits Target Influencer Campaigns

Over the past few months, two firms have filed a series of class action lawsuits against a number of companies – including Celsius, Shein, and Revolve – over their influencer campaigns. Leveraging the same template, the firms...more

FTC Issues FAQs on Fees Rule, Affirms Rule to Become Effective Next Week

The FTC issued FAQs to answer common questions about its Rule on Unfair or Deceptive Fees and to provide a small entity compliance guide in connection with the Rule. The issuance of the FAQs affirms that the current FTC, led...more

Lawsuit Turns the Heat up on Celsius Influencer Campaign

Feeling a little sluggish, a woman in California went onto Instagram to see what other people were doing to give themselves a little energy boost. When she learned that three of the influencers she followed – Devon Windsor,...more

Amazon Hit With Greenwashing Lawsuit

Last week, consumers in four states filed a proposed class action against Amazon, accusing the company of greenwashing by misleading consumers about the sustainability of the company’s Amazon Basics line of paper products....more

NAD Combs Through #1 Claims

Simpler Hair Color (or ​“SHC”) advertises that its products are ​“Rated #1 Men’s Hair Color” and ​“Rated #1 Men’s Hair & Beard Color” based on ​“Trustpilot​.com verified reviews.” Combe, a competitor, challenged the #1 claims...more

What’s Next for the Green Guides? Insights from Commissioner Holyoak’s Remarks at CPG

Green marketing is very much in vogue, and so is suing companies over their green marketing. If you want to avoid those suits, you should generally start by looking at the FTC’s Green Guides. But a lot has changed since the...more

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

P&G Accused of Greenwashing and Creating ​“Frankenforests”

Earlier this month, a group of eight consumers filed a class action against Procter & Gamble (“P&G”), alleging that the company is engaging in greenwashing by misleading consumers into thinking that its Charmin toilet paper...more

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

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

FTC Releases Narrowed Junk Fees Rule for Ticketing and Lodging

Fourteen months after proposing a far-reaching rule that would have overhauled the way fees are disclosed across sectors, the FTC today announced a significantly curtailed final rule limited to the sale of live-event tickets...more

FTC Delivers $2 Million Reminder About the Mail Order Rule

On Monday, the FTC announced a court order requiring GOAT – an online marketplace for sneakers, apparel, and accessories – to pay more than $2 million for violating the Mail Order Rule, which requires companies to have...more

With Uncertainty Surrounding the FTC’s Negative Option Rule, New California Requirements Wait in the Wings

Last Friday, the FTC’s final Negative Option Rule was published in the Federal Register, starting the clock on the effective dates for the agency’s expansive overhaul of requirements related to goods or services sold through...more

SDNY Reverses its Position on ​“Carbon Neutral” Lawsuit

In January, we reported that a judge in the Southern District of New York refused to dismiss a class action alleging that ​“carbon neutral” claims on bottles of Evian water were misleading. The judge determined that the term...more

FTC Staff Issues FAQs on the ​“Fake Review” Rule

As we noted in a previous post, the FTC’s Rule on the Use of Consumer Reviews and Testimonials, which went into effect on October 21, 2024, addresses deceptive conduct involving consumer reviews and testimonials and...more

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

LA Files a Lawsuit Alleging Plastic Recycling Deception as a Similar NY Suit is Dismissed

On October 31, 2024, LA County Counsel filed a lawsuit against PepsiCo and Coca Cola on behalf of California in an attempt to hold the companies ​“accountable for their role in the plastic crisis that is overwhelming the...more

[Webinar] Why You Should Care About the FTC’s Rule on Fake Reviews - September 10th, 12:00 pm - 1:00 pm ET

Join Kelley Drye Ad Law attorneys for an upcoming webinar: ​“Why You Should Care About the FTC’s Rule on Fake Reviews.” This session will break down the final rule announced by the FTC on August 14, 2024, designed to combat...more

FTC Finalizes Rule on “Fake Reviews”

Yesterday, the Federal Trade Commission announced its final rule addressing consumer reviews and testimonials. With this rule, the Commission takes aim at ​“fake” reviews and testimonials by prohibiting their sale or purchase...more

FTC Settlement with CarShield Holds Lessons on Endorsements

If you’ve watched the news recently, it’s fairly safe to predict that two things happened. First, you probably watched an announcer recount disturbing news about the current political climate. Second, following that segment,...more

FTC Settlement Illustrates Challenges with ​“Up to” Claims

“Up to” claims can be difficult to substantiate, in part, because the standard for substantiating those claims isn’t always clear. Over the years, the FTC, NAD, and courts have articulated different standards that are hard to...more

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