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
Controls oil production
Do Say These:
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
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.