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Advertising Substantiation: The FTC Policy Statement. Introduction. On March 1. Commission published a notice requesting comments on its advertising substantiation program. To facilitate analysis of the program, the notice posed a number of questions concerning the program's procedures, standards, benefits, and costs, and solicited suggestions for making the program more effective. Based on the public comments and the staff's review, the Commission has drawn certain conclusions about how the program is being implemented and how it might be refined to serve better the objective of maintaining a marketplace free of unfair and deceptive acts or practices. This statement articulates the Commission's policy with respect to advertising substantiation.
The Reasonable Basis Requirement. First, we reaffirm our commitment to the underlying legal requirement of advertising substantiation - that advertisers and ad agencies have a reasonable basis for advertising claims before they are disseminated. The Commission intends to continue vigorous. Objective claims for. These representations of. That is. consumers would be less likely to rely on claims for. Therefore, a firm's failure to possess and rely.
Section 5 of the Federal Trade Commission Act. Standards for Prior Substantiation. Many ads contain express or implied statements. When the substantiation claim is. Of course, an ad may. Absent an express or implied reference to a certain. Commission. assumes that consumers expect a .
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ADVERTISING SUBSTANTIATION PROGRAM (undated) . This statement was appended to the decision in Thompson Medical Co., 104 F.T.C. Title: FTC advertising substantiation program. Household products manufacturers. Documentation of Hakuhodo Advertising America, Inc.
The Commission's determination of. These factors include: the type of. Extrinsic evidence, such as expert testimony.
One issue the Commission examined was substantiation. Although firms are unlikely to.
Additional Information. Advertising Substantiation For additional information about advertising substantiation, please visit our sister site at www.advertisingsubstantiation.com. Advertising Substantiation Program - Paper.
The Commission will. Procedures for Obtaining. Substantiation. In the past, the Commission has sought substantiation. Commission's review indicates that . The Commission. intends to continue undertaking such law enforcement. However, since substantiation.
Commission's concern in such investigations is with the. Therefore, the. Commission anticipates that substantiation investigations. Accordingly, the Commission has determined that in the.
FTC POLICY STATEMENT REGARDING ADVERTISING SUBSTANTIATION Introduction. On March 11, 1983, the Commission published a notice requesting comments on its advertising substantiation program. Self substantiation is the act of a bluepill becoming aware of and/or escaping from the Matrix. Fan Contributor Program; WAM Score; Help; Can't find a community you love? Create your own and start something epic. Limited Purpose FSA Card Expense Substantiation Form: Instructions To substantiate a card purchase, you will need to supply a receipt that clearly proves the eligibility of a purchase made. Helicopter Life Substantiation: Review of some USA and UK Initiatives K.F. The Black Hawk life substantiation program is of special interest to the Royal Australian Air Force (RAAF). FTC POLICY STATEMENT REGARDING ADVERTISING SUBSTANTIATION Introduction. FTC POLICY STATEMENT REGARDING ADVERTISING SUBSTANTIATION.
The Commission believes that. The Commission. cannot presently foresee circumstances under which the. Relevance of Post- Claim Evidence in. Substantiation Cases. The reasonable basis doctrine requires that firms have. The. Commission has on occasion exercised its discretion.
The Commission has not previously. Such guidance can serve. The Commission emphasizes that as a matter of law. Section 5 of the FTC Act and are. The goal of the advertising.
Commission's deliberations. This does not mean that the Commission will. The Commission focuses. If available post- claim evidence proves that. Commission's resources. Second, post- claim evidence may indicate that apparent. In evaluating the.
Commission will. consider only post- claim substantiation that sheds light. Thus, advertisers will. Finally, the Commission may use post- claim evidence in. Thus, when additional evidence offered for the. Commission may frame a narrower order than if there had. The Commission remains committed to the prior.
The Commission will consider post- claim. But. whether it will do so in any particular case remains.
Self Regulation Groups and. Government Agencies.
The Commission traditionally has enjoyed a close. The. Commission will not necessarily defer, however, to a. An imprimatur from a. Commission prosecution, and an unfavorable. Commission will. automatically take issue, or find liability if it does. We. intend to continue our useful relationships with. By direction of the Commission.
For other chases, such as. FR 1. 04. 71, March 1. Nor presumably would an advertiser have made such claims unless the advertiser thought they would be material to consumers. Individual Commissioners have expressed differing views as to how claims should be interpreted so that advertisers are not held to outlandish or tenuous interpretations. Notwithstanding these variations in approach, the focus of all Commissioners on reasonable interpretations of claims is intended to ensure that advertisers arenot required to substantiate claims that were not made. The Commission's evidentiary rule, 1. C. F. R. 3. 4. 0, has sometimes been interpreted as precluding introduction of post- claim substantiation.
Section 3. 4. 0 only provides a sanction against the introduction of evidence that should have been produced in response to a subpoena, but was not.