Full Disclosure: Complying with the New FTC Guidelines

On March 12, the FTC released updated guidelines for making effective disclosures in digital advertising. Beauty & Fashion Tech posted a great article about why this is relevant to bloggers who receive free products for review and how to comply. You should go read the full post, as it goes into much more detail than I will here. My aim in this post is just to address how I have made disclosures in the past, and how I will make them in the future to comply with the new guidelines.

Essentially, receiving free products for review and then writing about them is considered advertising. All advertising online must be disclosed in a clear, conspicuous manner. This is relevant to me, as a book blogger, because I sometimes receive free copies of books from publishers and authors in order to review them for my blog. Since I am writing about books that were provided for review, I need to disclose my relationship with the publisher/author who provided the book.

In the past, when I have reviewed a review copy, I have included the disclosure, “I received a complimentary copy of this book from the publisher/author in exchange for my honest review” at the bottom of the post. After reading the updated guidelines, I have decided to take a few measures to increase transparency.

The FTC guidelines require ads to be designed so that scrolling is not necessary in order to find the disclosure. Additionally, disclosures should be placed as close to the endorsement as possible and should be located before any links to buy the product. The guidelines also note that Websites and mobile apps that display information on multiple pages (such as posts that include the body of the article “after the jump”) may affect proximity.

To address issues of proximity, I will add a “source” line to the book info I provide at the beginning of my posts. My book reviews will now look like this:

BOOK TITLE
Author’s Name
Publisher, release date
Format (paperback, hardcover, etc), number of pages
Source (publisher, author, book tour group)

This will let readers know right away if I received a book from a publisher, bought it myself, got it from the library, etc. I will still include the full disclosure at the end of my posts, but this way readers will know before reading the full post — or before even clicking through from my blog’s homepage — whether I received the book for free.

The guidelines also give requirements for disclosure in “space-constrained” messages, such as social media. If you endorse the product in your tweet, you must disclose that you received the product for free; however, tweeting something like, “Review ofย Book Titleย byย Author,” followed by a link to your post does not explicitly endorse the book and is acceptable. I usually tweet links to my reviews with neutral language as in the previous example, but in the future I will make sure to include a disclosure along the lines of, “ARC courtesy of @Publisher,” if I directly recommend the book in my tweet.

If you receive books to review, what changes are you making to increase transparency? How will the updated guidelines affect the way you blog?

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17 thoughts on “Full Disclosure: Complying with the New FTC Guidelines

  1. This is very interesting. I started receiving review copies last June and felt, well, lucky. I was getting only the ones I was asking for, actually I don’t review books I haven’t directly asked the publisher for. If I were paid by a magazine or a newspaper, of course I would review what they’d ask me, but I’m a blogger, so I review what I want and nothing more.

    I always write in the introductory paragraph to my review whether it was bought or the publisher sent it to me along with my thanks for well, sending me the free books I want.

    • I sometimes accept review copies pitched to me by authors and publicists if they appeal to me; often, they are books published by small presses, and I love supporting indies in any way I can!

      I really like the way you introduce your books! As far as disclosures go, it’s a great way to personally and thankfully acknowledge that the book was provided for review ๐Ÿ™‚

  2. I’ve been putting the disclaimer at the bottom of each post, and of course have something written on my policy page. I like the format you’re planning to use, I think I’m going to do something similar. I want to be transparent and in compliance with the FTC, but I don’t want to clutter up the content, either (if that makes sense). Great post, thanks!

    • Oh, I hadn’t even thought about how adding disclosures could clutter up the content; that’s definitely something to consider when placing disclaimers. I’m glad you liked it! Thanks for stopping by ๐Ÿ™‚

  3. Do you think this applies to NetGalley? The only books I get to review are NetGalley books, and they are the e-versions that usually aren’t even in publication form. All other books are my own.

    • I think it does apply to NetGalley books. The guidelines say that any product received for free to review must be disclosed; I don’t think it makes a difference whether it’s a physical book or an e-book. I haven’t used NetGalley, so I don’t know exactly how it works, but my understanding is that you can put in requests for books you want to review, and then the publisher can approve your request and send you the galley in e-book form? I think this would fall under the category of “digital advertising,” since the publisher is sending you an e-galley in return for publicity.

      • Yes, that’s how it works. I always mention that I received the book from NetGalley in the beginning of my posts. I’ll make sure I add in a “to review” part or something like that.

  4. I have a source line in my reviews as well. I have a disclosure on my About page that mentions my affiliate relationships as well. I hope that does the trick!

  5. Thanks for this informative post! I found this entry through Elena on Twitter ๐Ÿ™‚ I’ve only started receiving ARCs maybe last year, first through GoodReads giveaways and other online contests but now I’ve started getting them a bit more regularly through NetGalley and more recently through a blogger’s programme. I’ve always mentioned in my introduction to my reviews if I’ve received a copy through a publisher or a giveaway but I’ve been thinking for some time how else to make it more visible and my blog more organised. The idea of mentioning the “source” somewhere at the start is definitely a good idea, I might do that as well as it’s the clearest *nods*

  6. Great post, Leah! I put the disclaimer at the bottom of the review ,but you are right! It should be more clear before someone’s reads the post and I think the publisher/author will also appreciate it if the disclaimer is on top as oppose to being mentioned as a “by the way” I received this in exchange for a honest review.

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