October 29, 2025
By:
Asa Waldstein
Product Review Best Practices
Takeaway -
Use caution when using product reviews in marketing
I am often asked if third-party product reviews are considered marketing, and the answer is “it depends.” Here are some best practices and considerations when soliciting and using third-party reviews.
If product reviews are displayed on a website, FDA and FTC typically take a “hands-off” approach as long as the reviews meet the following criteria:
- Third-party: A third-party review should come from people not affiliated with the company in any formal or compensated capacity, unless this is clearly disclosed. This includes employees, brand ambassadors, or anyone with a vested interest.
- Reviews Must Reflect Honest Opinion: Consumers must have used the product and be reporting their true experience. FTC has brought cases such as with Google and iHeartRadio, where endorsers promoted products they had never used, and this was deemed deceptive.
- Uncurated: Be careful not to selectively highlight only positive feedback. Even gathering reviews on a dedicated “Reviews” page may be viewed as curation.
- Not solicited: FTC prohibits misleading reviews that are secretly or deceptively incentivized, such as “free product in exchange for a favorable review.”
- Uncompensated: Ensure product reviewers clearly disclose any material connection, such as free products or paid ambassadors. This FTC case against sugar influencers and trade groups has some good teaching lessons.
- Not showcased: Avoid featuring reviews in banners, ads, or social media images. This is where many companies get into trouble. I recently reviewed a client’s website where the website’s code pulled third-party reviews into a banner. There was an Alzheimer’s claim on the banner! This is bad!
- No engagement: Don’t respond or engage with disease-containing reviews on websites or social media. Engaging, including “saying thanks,” turns reviews into marketing.
- No suppression of negative reviews: Don’t hide unfavorable reviews. FTC issued a $4.2 million fine against Fashion Nova for this practice.
Disclaimer: The educational information provided here is for informational purposes only. Contact an attorney for specific legal advice. Rule #1 in compliance is to ensure marketing is truthful and not misleading.
Written by
Asa Waldstein
Asa Waldstein is a 24-year veteran of the dietary supplement industry, with experience spanning manufacturing, marketing, and regulatory compliance. He is the principal of Apex Compliance, a software company dedicated to streamlining regulatory marketing compliance for the dietary supplement and natural products sectors. Asa also leads Supplement Advisory Group, a boutique consultancy focused on marketing risk analysis, labeling, and practical compliance strategies for websites and social media. Asa has helped oversee three FDA GMP inspections with no 483s and was honored with the 2023 AHPA Herbal Hero Award and the 2024 What's Up Supps Policy and Change Agent Award. He currently serves as Chair of the American Herbal Products Association’s (AHPA) Technology & AI Innovation Committee.