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Unformatted text preview: ly labeled. A-14 Federal Trade Commission Example 13
If the purchase or use of the advertised product entails significant additional charges
beyond the basic price of the product and consumers reasonably might not expect those
charges, they should be disclosed prominently on the same page as, and immediately adjacent
to, statements of the product’s basic cost.
In this example, disclosure of the existence and amount of a monthly monitoring fee
only on the check-out page (see next page) would likely be deemed insufficiently clear and
conspicuous; this fee should be clearly stated next to the price of the cameras on the preceding
website pages that provide that price information. (continue on next page) A-15 .com Disclosures: How to Make Effective Disclosures in Digital Advertising Example 13 (continued)
However, disclosure on the check-out page of the sales tax the consumer owes on this
purchase, as well as reasonable shipping and handling charges, would not be problematic,
because consumers expect these charges. A-16 Federal Trade Commission Example 14
This space-constrained message requires two disclosures: (1) that JuliStarz is a paid
endorser for Fat-away; and (2) the amount of weight that consumers who use Fat-away
can generally expect to lose in the depicted circumstances, which is much less than the 30
pounds Juli says she lost in 6 weeks. See Guides Concerning the Use of Endorsements and
Testimonials in Advertising, 16 CFR Part 255.
Even if the link in the message led directly to those disclosures on the Fat-away website,
those disclosures would not be adequate if consumers could purchase Fat-away at a brick and
mortar store or from a third-party online retailer (a retailer that is not affiliated with the advertiser).
In either case, they might not click through to the Fat-away website, and thus would not see
these disclosures. A-17 .com Disclosures: How to Make Effective Disclosures in Digital Advertising Example 15
In some cases, required disclosures can easily be incorporated into a space-constrained
ad. This space-constrained message requires two disclosures: (1) that JuliStarz is a paid
endorser for Fat-away; and (2) the amount of weight th...
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- Spring '14