Supplement e-commerce: fake reviews, insider testimonials and what the label must still carry
Keep reviews honest, disclose every material connection, and make sure the listing shows the label with its US adverse event contact.
In Short
- No reviews bought for a sentiment.
- Insiders must disclose ties.
- Label: US contact for AER reports.
Online supplement listings live or die by reviews, and the FTC now has a rule on how businesses may get and show them. This guide reads that rule, the FTC's endorsement guides and one label duty that still applies online. Opened: eCFR 16 CFR part 465 and part 255, up to date as of 1 Oct 2026, and GovInfo 21 U.S.C. 343(y) (2023 edition). Not opened: Amazon, Shopify, TikTok, Meta or Google seller policies, FTC business guidance and enforcement actions, FDA guidance on online labeling and state laws. Platform rules are contracts that change often; check each one you sell on. It is orientation, not legal advice. Sources checked 5 Oct 2026.
Fake and Bought Reviews
16 CFR 465.2 makes it a violation for a business to write, create or sell a consumer review or testimonial that materially misrepresents that the reviewer exists, used the product, or what their experience was. It also covers buying such reviews or spreading testimonials the business knew or should have known were false, and procuring reviews from its own officers, managers, employees or agents, or their relatives, in the same circumstances.
Is this review practice allowed? (simplified 16 CFR 465)
- 465.4: incentive tied to sentiment.
More on fake and Bought Reviews
465.4 prohibits offering compensation or other incentives conditioned on a review expressing a particular sentiment, positive or negative.
Insiders and Company-Controlled Sites
Under 465.5(a), an officer or manager who writes a review or testimonial about the business must clearly and conspicuously disclose the material relationship, unless for a testimonial the relationship is otherwise clear. 465.5(b) covers testimonials by employees and agents that the business spreads without disclosure, with exceptions for general requests to purchasers and for simply hosting reviews.
Influencer and Review Programme Record
More on insiders and Company-Controlled Sites
465.6 prohibits presenting a website or organisation the business controls as providing independent reviews or opinions about a category that includes its own products.
Suppression and Fake Influence
465.7(a) prohibits using unfounded legal threats, physical threats, intimidation or knowingly false public accusations to stop a review being written or to get it removed. 465.7(b) prohibits a business misrepresenting that the reviews shown on its site represent most or all reviews submitted, when reviews are being suppressed based on their rating or negative sentiment.
More on suppression and Fake Influence
465.8 prohibits selling or buying fake indicators of social media influence, such as followers or views, that the person knew or should have known were fake, to misrepresent influence for a commercial purpose.
Endorsements and Influencers
Part 255 is the FTC's Guides Concerning Use of Endorsements and Testimonials in Advertising. Unlike part 465, it is a set of guides.
More on endorsements and Influencers
It covers, among other things, disclosure of unexpected material connections between an advertiser and an endorser in 255.5, and examples where an advertiser is liable for a deceptive endorsement claim even when the endorser is not. For supplements, an influencer's health statement is still the brand's claim. Keep the substantiation file for every claim an endorser makes, and record the disclosure each agreement requires.
The label still has a job
21 U.S.C. 343(y) says a dietary supplement marketed in the United States is misbranded unless its label includes a domestic address or domestic phone number through which the responsible person may receive a report of a serious adverse event.
Worked Example: Listing Check for SKU EC-512
| Check | Status |
|---|---|
| Listing image matches approved label version | Yes, v4 |
| US address or phone on label | Yes |
| Platform messages routed to adverse event owner | Weekly check |
- Listing image matches approved label version
- Status
- Yes, v4
- US address or phone on label
- Status
- Yes
- Platform messages routed to adverse event owner
- Status
- Weekly check
More on the label still has a job
Listing images should match the current approved label, including that contact. Reports that arrive through a platform's messages or reviews still need routing to the person who handles adverse events. This guide did not open platform reporting tools or the adverse event reporting statute itself; see the adverse event reporting guide.
Questions
Can we offer a discount for leaving a review?
16 CFR 465.4 prohibits incentives conditioned on a review expressing a particular sentiment. Whether a neutral incentive programme is acceptable under each platform's rules was not checked here.
Can staff post reviews of our products?
Officers and managers must clearly disclose their material relationship under 465.5(a), and 465.2(c) bars procuring employee reviews the business knew or should have known misrepresent experience.
Is Part 255 binding like Part 465?
Part 255 is titled Guides Concerning Use of Endorsements and Testimonials in Advertising, while part 465 is a rule. Both were opened; how they interact in enforcement is a question for counsel.
Does V5 moderate our reviews?
No. V5 keeps label versions, claim files and adverse event records linked to lots. Your marketing and legal teams decide what you publish online.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
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