Richard Starr

Richard Starr

Venable LLP

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NAD Issues Decision Addressing “Clean,” “Ethically and Sustainably Sourced,” and Efficacy Claims for Amyris Clean Beauty, Inc....

Earlier this month, the National Advertising Division of BBB National Programs (NAD) recommended that Amyris Clean Beauty, Inc.’s (Amyris) Biossance skincare products modify or discontinue several claims regarding their...more

3/18/2024  /  Advertising , Certifications , Ethical Standards , Marketing , NAD , Personal Care Products , Product Labels , Sustainability

In “Made in America” Case NAD Finds That Advertisers Should Not Rely on Disclosures to Cure a False or Misleading Claim

The National Advertising Division of BBB National Programs (NAD) recommended last month that Stihl Incorporated USA (Stihl), a manufacturer of equipment and tools, discontinue or modify its unqualified “Made in America”...more

3/14/2024  /  Advertising , Disclosure , False Advertising , Made in the USA , Misleading Statements , NAD

FTC Brings the Heat on Pyrex Manufacturer’s “Made in USA” Claims for Products Made in China

Last week the Federal Trade Commission (FTC) announced it had issued a complaint and proposed consent order against Instant Brands LLC for allegedly marketing products as “Made in the USA,” when they were actually made in...more

1/24/2023  /  Advertising , Consent Order , Corporate Counsel , Country of Origin , Enforcement Actions , False Advertising , Federal Trade Commission (FTC) , Labeling , Made in the USA , Manufacturers

FTC Announces Health Products Compliance Guidance

On December 20th, 2022, the Federal Trade Commission published new guidance regarding claims about the benefits and safety of health-related products: Health Products Compliance Guidance. This guidance replaces the...more

12/22/2022  /  Advertising , Compliance , Dietary Supplements , Disclosure Requirements , Federal Trade Commission (FTC) , Food and Drug Administration (FDA) , Health Claims , New Guidance , Prescription Drugs

FTC Seeks Public Comment on Possible Green Guides Revisions

At its December 14, 2022 open meeting, the Federal Trade Commission announced it would publish a notice in the Federal Register seeking comment on potential updates or revisions to its existing Green Guides. The Green Guides...more

12/16/2022  /  Advertising , Federal Trade Commission (FTC) , Green Guides , Green Marketing , Greenwashing , Marketing , Notice and Comment , Rulemaking Process , Sustainability

Takeaways from NAD 2022: The FTC’s Enforcement Priorities, New Technologies, Dark Patterns, and the Usual Suspects

​​​​​​​Last week, the National Advertising Division of the Better Business Bureau National Programs (NAD) held its annual conference. The wide array of speakers covered a broad range of topics, from the metaverse to dark...more

9/27/2022  /  Advertising , Disclosure Requirements , Enforcement Priorities , Federal Trade Commission (FTC) , Metaverse , NAD , Online Advertisements , Technology , Trade Conference
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