FTC

How to Write Copy That Meets FTC Compliance

How to Write Copy That is FTC Compliant

One thing that is universal in the beauty industry right now? Concern over Federal Trade Commission (FTC) regulations. Big name companies like Goop coming under fire for misleading advertising has been a wake up call for small businesses and large retailers. Do you know how to write your own copy and make sure it meets FTC compliance?

Even if you hire most of your copywriting work done for you, there will still be times when you need to come up with some brand words on your own. And when you do, it’s handy to know how to write in a way that is FTC compliant.

The problem with FTC compliance is that all of this is pretty ambiguous. I called both the Food and Drug Administration (FDA) and the FTC to get the down and dirty on writing copy for natural beauty brands and retailers (that is my bread + butter, after all), and after being rerouted several times and turned down for comment once (!) I did get some decent info and have since compiled my own guide to writing for FTC compliance.

So, today I am sharing with you my guidelines on staying out of trouble with the FTC when writing for your website, email campaign, or social media, while still sounding like a real human being.

How to Write Your Own Copy That is FTC Compliant (A Guide to Keeping You Out of Trouble)

I’ll shoot it to you straight — this subject gets pretty in depth. In other words, there’s a legit learning curve here. I’ve spelled it out below as concisely as possible. Believe me, it is worth it to learn the ins and outs of this stuff.

What is FTC compliance? First of all, it’s helpful to understand what’s behind these regulations. The FDA regulates cosmetic product labeling. The FTC regulates cosmetic marketing and advertising, which includes product description and sales pages, blog posts, printed materials, social media, and how product ingredient, products, and uses are described. Yes, you read that right, social media posts count too. (that’s one tidbit I did get out of a representative at the FDA)


The FTC pays closest attention to ads that make claims about health and safety, like “this sunscreen will reduce the risk of skin cancer”.


Many brands run into trouble with misleading claims. Remember, according to the FDA definition of a cosmetic product, it cannot claim to treat or prevent disease, or affect or alter the structure or functions of the human body in any way. The FTC pays closest attention to ads that make claims about health and safety, like “this sunscreen will reduce the risk of skin cancer”.

Another hot button area for the FTC is with essential oils and aromatherapy claims. Steer clear of saying that EOs will help your customer sleep, get rid of anxiety, quit smoking, get rid of headaches … you get the picture.

Even if you aren’t making anti-cancer claims, it is still important to stick with FTC regulations when writing about cosmetics. Claims that a product will eliminate wrinkles, prevent acne, cure rosacea, or anything else that does more than affect the appearance or feel of skin or hair is considered misleading advertising.

What you can say: Under FDA rule, cosmetics can beautify, cleanse, promote attractiveness, and alter the appearance. In order to stay within FTC guidelines, it’s important to tell the story of the product in terms of how it makes the skin, hair, and body look, feel, and smell.

How do you keep from writing copy that sounds awkward or boring? This is a good question and one I’ve been asked by clients before taking on a project. Remember, tell the story. If you were to use a facial serum, how does it feel in your hands when you apply it to your skin, how does it make your skin feel, how does it smell, how does your skin look right after you apply the product, how does your skin look after using the product for a couple of weeks?

The bottom line is consumer perception. After reading your product description, will the consumer feel the product is intended to make their skin look radiant and youthful, or that it’s going to eliminate wrinkles and reverse aging? There’s a big difference when it comes to FTC compliance.

How natural is it? The terms “100% natural” and “all natural” are also no-nos when writing for FTC compliance. You can say that organic ingredients are organic, or that organic or natural ingredients are used to make the product. But because the term “natural” has no legal definition, all natural and 100% natural should be avoided.

A Snapshot of Dos and Don’ts to Use In Your Copy

Don’t Say These:

Eases pain/disease/skin issue
Prevents pain/disease/skin issue
Heals pain/disease/skin issue
Treats pain/disease/skin issue
Helps sleep/stop smoking/lose weight
Kills bacteria
Controls oil production

Do Say These:

Cleanses skin/hair
Conditions skin/hair
Moisturizes skin/hair
Lessens/diminishes the feeling of…
Lessens/diminishes the look/appearance of…
Improves the look/appearance of…
Makes skin look better
Reduces signs of …
Makes skin feel better
Beautifies

Yes, it’s a lot to take in and it’s a lot of work, not gonna lie. But since you can get your fanny in a jam by not taking time to figure this out, it’s the only way to go when writing any ad copy for your business.

Have questions? Get in touch and I will help guide you on your path to writing for FTC compliance.

How To Avoid the Writing Errors That Put Gwyneth Paltrow Under Investigation

How To Avoid the Writing Errors That Put Gwyneth Paltrow Under Investigation

Uh-oh. Looks like Gwyneth Paltrow is getting some public flogging over her health and wellness website, Goop, once again. She’s taken flack over the sometimes silly-seeming products she promotes, but this time it’s not coming from consumers and bloggers. Or even Martha Stewart.

It looks like Goop may be in trouble with the Federal Trade Commission (FTC). Those of us who are beauty bloggers recognize these guys as the ones who make us put up those disclaimers telling our audience things like “this post is sponsored by …” or “there are affiliate links in this post from which I receive a small compensation”. Yep, if you’ve ever wondered why we bother with those obtrusive disclaimers, it’s the FTC.

While the Food and Drug Administration (FDA) governs cosmetic labeling, the FTC regulates advertising claims. This includes product descriptions on brand websites.

As a beauty copywriter I am very familiar with FTC regulations. Basically, when marketing a cosmetic product for sale you cannot describe the product as altering or affecting the structure or function of a human body, or curing or preventing disease or health issues. In the eyes of the FDA, drugs do those things, cosmetics do not.

Even if I absolutely swear a client product has done something amazing to my skin, like made it firmer or erased a wrinkle, I can’t say that in the product description I write for them. It has to be all about making the skin look and feel more attractive. That’s the law.

But it looks like the copywriting team at Goop missed the memo. I love to read the health articles at Goop and Jean Godfrey-June has long been my beauty editor idol. The problem isn’t with the articles recommending products or remedies, it’s when health claims are used to market the products, as in product descriptions on sales pages.

For example, one of the products in question is a flower essence blend that can be used on the skin for “trauma repair”. The trouble spot is “this formula helps clear, stabilize and soothe emotional trauma.” They could have said “this formula lends a feeling of clarity, stability, and soothing to emotional trauma.” (I’m also a fan of the Oxford comma 😉) or “designed to offer a clear, stabilized, and soothing feeling to mind and body.” Either of those would have worked with FTC law but making health claims is the no-no.

Another example is a moisturizer on the site that is said to “work throughout the day to firm and rejuvenate the skin.” It can “give the feeling of firmer, rejuvenated skin” or “increase the appearance of firmer, rejuvenated skin” under FTC law, but it cannot claim to physically alter the skin.

If all of this is a bit too word nerd for you, the main issue is this. If you read any cosmetic product advertising that claims to improve your health or the actual structure of your skin, it is in violation of FTC laws. Authentic natural beauty brands know this and product descriptions that follow FTC regulations are proof you are dealing with a pro.

If you are a natural beauty brand or shop owner who would like help coming up with product descriptions that won’t get you in trouble with the FTC, contact me. It can be tricky to work within these guidelines and not repeat the same words and phrases over and over. I’m well versed in FTC laws and would love to help you put together fresh product descriptions that are as creative as they are legal. Let’s talk!

Photo by Lauren Mancke on Unsplash