Free Product Campaign Evidence and Disclosure Record

Free Product Campaign Evidence and Disclosure Record

The transcript establishes that Dalton supplied apparel after informal conversations about posting. It does not establish written acceptance, exact deliverables, product-fit procedures, content rights, disclosure instructions, monitoring, or the intent of any recipient.

FTC guidance says a free or discounted product can create a material connection that should be disclosed when the recipient endorses the product. The disclosure should be hard to miss and use clear language. The FTC also states that endorsements must be honest and cannot make claims the marketer could not legally make.

The current questions-and-answers page discusses advertiser instructions, tagging, preapproval, and monitoring. It does not create one mandatory contract form.

A commercial agreement and a public disclosure solve different problems. Terms establish what the parties accepted. Disclosure tells the audience about a relationship that could affect how the message is evaluated.