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Claim Substantiation

The documented evidence supporting advertising claims, required before claims are made in advertising by both the FTC and platform policies.

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What Claim Substantiation means

Claim substantiation is the process of gathering and maintaining evidence that supports advertising claims before those claims are published. The FTC's substantiation doctrine, established in Pfizer (1972), requires advertisers to possess a 'reasonable basis' for objective claims at the time they are made. The level of substantiation required depends on the claim type: health claims require competent and reliable scientific evidence (typically randomized controlled trials), performance claims require appropriate testing, comparative claims require head-to-head data, and testimonials must represent typical results. Platforms enforce substantiation requirements through their review processes and may request evidence. Best practices include maintaining a substantiation dossier for each claim, having claims reviewed by legal counsel before publication, training creative teams on substantiation requirements, and establishing claim approval workflows. Substantiation failures are among the most common FTC enforcement triggers.

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