Checklist · Commercial

Clearing an Advertising Campaign: A Substantiation and Disclosure Checklist

15 U.S.C. § 45

Type: Checklist
Jurisdiction: National
Date: 2025-01-22
Topic: Commercial

A phase-by-phase operational checklist for clearing an advertising campaign before it runs and defending it after it does. Twelve phases move from intake and scoping, through building a claim inventory that captures implied as well as express messages, through substantiation review against the competent and reliable scientific evidence standard, comparative and superiority claim testing, disclosure design in the actual delivery medium, endorser and influencer program controls, review and ratings practices under the FTC consumer reviews rule, the specialty regimes governing origin, environmental, and health claims, pricing and offer mechanics, subscription and negative option flows under ROSCA and the state auto-renewal statutes, sign-off and record retention, and the first seventy-two hours after a challenge arrives. Each phase carries commentary explaining the failure mode and the traps that convert a routine campaign into an enforcement matter. A worked example follows a fictional consumer products company through a launch it nearly got right.

Clearing an Advertising Campaign: A Substantiation and Disclosure Checklist

Commercial > Advertising and Marketing | Published 22 January 2025 - Updated 27 June 2026 | UpLaw - uplaw.us

In brief. Advertising clearance is not a legal review of finished creative. It is a claim-by-claim reconciliation between what the copy conveys and what the file can prove, run before dissemination, because the law requires the proof to exist first. Nine times out of ten the deliverable is a deletion, and the deletion is free. After launch, nothing is.

Keywords: claim inventory, substantiation file, establishment claims, net impression, comparative testing, clear and conspicuous, Part 255, Part 465, Made in USA, Green Guides, reference price, ROSCA, dark patterns, NAD, CID

How to use this. Phases 1–5 are the core clearance sequence and apply to every campaign. Phases 6–10 are the specialty screens — run the ones that apply, and note that most enforcement lives here. Phase 11 is sign-off and records. Phase 12 is the response when someone challenges the campaign. The doctrine is in Advertising and Marketing Law: A Comprehensive Guide to Substantiation, Endorsements, and Claims. The narrative introduction is Puffery, Substantiation, and the Reasonable Consumer: Where Ad Claims Actually Fail. The resource map is The Advertising and Marketing Law Toolkit.

A standing caution. Federal law is the floor. State auto-renewal, environmental marketing, price-comparison, and fee-disclosure statutes are frequently stricter, several carry private rights of action and multiplied damages, and industry regulators (FDA, FCC, TTB, state insurance and bar advertising rules, FINRA) displace the general regime in their domains. Clear against the strictest applicable standard.

Phase 1 — Intake and Scoping

[ ] Obtain the full creative set, not a deck — every execution, every cut-down, every placement size, every localization.
[ ] Identify each medium: broadcast, connected TV, paid social, organic social, email, SMS, display, out-of-home, packaging, point of sale, podcast, livestream, in-app.
[ ] Identify the target audience, including whether the campaign reaches children, teens, patients, servicemembers, or the financially distressed.
[ ] Identify the product category and whether an industry regulator has jurisdiction over the claims.
[ ] Identify the launch date and calendar clearance backward from it with a real buffer.
[ ] Identify every participant: brand team, agency, production company, influencer network, affiliate program, retail partner, testing lab.
[ ] Confirm who has authority to approve claims and that no one else can push creative live.
[ ] Ask what the campaign is meant to make consumers believe — the answer is the implied-claim list, given voluntarily.
[ ] Ask whether any competitor is named, shown, or identifiable.
[ ] Request the prior campaign's clearance file and any past challenges, demands, or regulatory correspondence.
[ ] Confirm whether the client has received an FTC penalty offense notice on endorsements, earnings claims, or reviews.

Why it matters, and the traps. Clearance run on a deck rather than the finished assets misses the claims that live in imagery, sequencing, and on-screen text — which is where implied claims are born. The second trap is scope: a fifteen-second vertical cut of a compliant thirty-second spot routinely drops the disclosure, and nobody re-clears it because it is "the same ad." It is not the same ad. Every execution in every aspect ratio is a separate advertisement.

Phase 2 — Building the Claim Inventory

[ ] Create one row per claim as a consumer will understand it, not as the copywriter wrote it.
[ ] Separate express claims from implied claims and record both.
[ ] Derive implied claims from the net impression: imagery, demonstrations, before-and-after visuals, juxtaposition, music, and what the ad conspicuously omits.
[ ] Flag every establishment word: proven, tested, clinically, laboratory, doctor recommended, guaranteed, certified, verified.
[ ] Flag every superlative and comparative: best, most, #1, leading, faster, quieter, longer-lasting.
[ ] Flag every quantified claim and record the exact test conditions behind the number.
[ ] Flag every health, safety, or efficacy claim, however casual.
[ ] Flag origin, environmental, and price claims for the specialty screens.
[ ] Flag "up to," "helps," "supports," and "may" — hedges narrow claims less than marketers assume.
[ ] Note the materiality of each claim; presume it for express claims and for efficacy, safety, price, and central attributes.
[ ] Where an implied claim is contestable, plan copy testing rather than argue about it internally.
[ ] Circulate the inventory to the brand team and ask them to add any claim they intend consumers to take away.

Why it matters, and the traps. The claim inventory is the single artifact that determines outcomes. Regulators, competitors, and plaintiffs all ask for it by name, and its absence is itself evidence of the violation, because substantiation must exist before dissemination. The dominant trap is inventorying only express claims. Advertisers substantiate what they wrote down and get sued for what consumers heard — a gap that copy testing closes for a few thousand dollars and litigation closes for seven figures.

Phase 3 — Substantiation Review

[ ] For each claim, identify the specific evidence relied on, cited to page, table, or figure.
[ ] Confirm the evidence exists now and is in the client's possession, not promised.
[ ] Apply the Pfizer factors: product type, claim type, consequences of falsity, cost of substantiation, and what experts in the field would require.
[ ] For health, safety, and efficacy claims, test the evidence against competent and reliable scientific evidence: human subjects, randomization, control, blinding where endpoints are subjective, adequate sample, matched endpoints, realistic use conditions.
[ ] Confirm the endpoint measured matches the benefit claimed — the most common substantiation failure by a wide margin.
[ ] Confirm the test conditions resemble consumer use, not laboratory maxima.
[ ] Review the totality of the evidence, including unfavorable studies, and document the weighing.
[ ] For establishment claims, confirm the evidence is of the type and quantity the phrase promises, per Removatron and Thompson Medical.
[ ] Confirm no claim rests on placebo-susceptible self-report alone — FTC v. Pantron I Corp., 33 F.3d 1088 (9th Cir. 1994).
[ ] Confirm the lab was qualified and independent, and obtain the full protocol, not the summary.
[ ] Record every gap between claim and evidence and either narrow the claim or delete it.
[ ] Date and sign the file; retain it for the applicable limitations period plus the life of the campaign.

Why it matters, and the traps. Substantiation is a timing rule: the reasonable basis must be possessed at dissemination, so a file assembled after a demand letter proves the violation instead of rebutting it. The recurring trap is the summary memo from a testing lab. It says the product performed well; the underlying protocol shows maximum settings, a sealed chamber, and a single pass. Always read the protocol, and always ask what the study would have had to look like to support the sentence in the ad.

Phase 4 — Puffery, Comparative, and Superiority Claims

[ ] For each superlative, ask whether it is specific, measurable, and falsifiable. If yes, it is not puffery.
[ ] Check context: a vague boast placed beside a data chart becomes a comparative performance claim — Pizza Hut, Inc. v. Papa John's International, Inc., 227 F.3d 489 (5th Cir. 2000).
[ ] For head-to-head claims, confirm the comparator is the current formulation or model the consumer would buy.
[ ] Confirm the test protocol matches the claim's scope — attribute, conditions, duration, and population.
[ ] For "#1" or "best-selling," fix the metric, market, period, and source, and calendar the claim's expiration.
[ ] For parity claims, confirm the study was designed as an equivalence test, not a failed superiority test.
[ ] For "up to" claims, confirm an appreciable proportion of users achieve the stated maximum.
[ ] Confirm any depicted demonstration is genuine and any mock-up is disclosed — FTC v. Colgate-Palmolive Co., 380 U.S. 374 (1965).
[ ] Confirm the ad does not falsely disparage a competitor's product or make claims about the competitor's business.
[ ] Assume the competitor will retest and challenge; write the claim to survive that retest.
[ ] Preserve the complete comparative test package in a form producible to NAD within fifteen business days.

Why it matters, and the traps. Puffery is a claim-identification argument, not an immunity: it asserts the ad conveys no factual claim at all, which fails the moment context supplies one. The comparative trap is protocol drift — a study designed for R&D purposes, repurposed as advertising support, that tested a superseded competitor model under conditions no consumer experiences. NAD finds this in a week, and the remedy is discontinuance plus a published decision your next adversary will cite.

Phase 5 — Disclosure Design

[ ] List every disclosure the claims require and draft the exact wording.
[ ] Place each disclosure proximate to the triggering claim, not in a footer or terms block.
[ ] Match the modality: visual disclosure for visual claims, audible for audible, both for both.
[ ] Confirm the disclosure is unavoidable — no hyperlink, hover, scroll, or "more" expansion for material terms.
[ ] For video, confirm duration sufficient for an ordinary viewer to read and understand at normal speed.
[ ] Confirm contrast, size, and background in the actual rendered asset, not the design file.
[ ] Confirm nothing elsewhere in the ad contradicts or mitigates the disclosure.
[ ] Review the disclosure on a phone, at the size and in the feed where it will run.
[ ] Confirm the disclosure language is understandable to ordinary consumers and appears in the ad's language.
[ ] If the format cannot carry a required disclosure clearly and conspicuously, change the claim or drop the format.
[ ] Screenshot every rendered execution with the disclosure visible and retain it.

Why it matters, and the traps. Clear and conspicuous is a functional standard, not a typography rule: the question is whether ordinary consumers actually notice and understand. Two traps recur. First, the design-file review — legal approves a comp at 200% zoom that renders illegibly in-feed. Second, the belief that a disclosure can rescue a false claim. It cannot. A disclosure clarifies an ambiguous claim; it never cures an unambiguous misleading one, which is the practical lesson of McGinity v. Procter & Gamble Co., 69 F.4th 1093 (9th Cir. 2023).

Phase 6 — Endorsers, Influencers, and Employee Advocacy

[ ] Confirm every endorser has actually used the product where the ad so implies, and for the period stated.
[ ] Confirm the endorsement reflects the endorser's honest opinion.
[ ] Substantiate every claim the endorser makes as if the brand made it — it did, for legal purposes.
[ ] Confirm depicted results are what consumers generally achieve; a "results not typical" disclaimer does not cure — 16 C.F.R. § 255.2(b).
[ ] Require material connection disclosure in the first lines of a caption, superimposed on video for the relevant duration, and spoken in audio.
[ ] Reject ambiguous tags: #sp, #collab, #thanks, #ambassador alone are insufficient.
[ ] Put the disclosure obligation, an approved claim sheet, and a prohibition on unapproved claims in the written agreement.
[ ] Deliver training and retain acknowledgments.
[ ] Confirm expert endorsers actually possess the expertise and conducted an evaluation an expert would conduct.
[ ] Treat employees posting about the employer's products as endorsers and cover them by policy.
[ ] Apply the same rules to affiliate links, commission programs, and gifting seeding lists.
[ ] Implement monitoring of posted content and a documented correct-or-remove process.
[ ] For child audiences, confirm the disclosure is comprehensible to a child and satisfies CARU guidance.

Why it matters, and the traps. The advertiser owns the endorser's claims, the endorser's disclosure failures, and the gap between the endorser's stated experience and reality. The trap that generates the most exposure is monitoring: brands negotiate excellent contracts and never check what got posted. A program with a contract, a claim sheet, training records, and evidence of actual monitoring is defensible even when a creator misbehaves. A program with only a contract is not, and the contract becomes the document proving the brand knew what was required.

Phase 7 — Reviews, Ratings, and Social Proof

[ ] Map how reviews are solicited, and confirm no incentive is conditioned on sentiment — 16 C.F.R. § 465.4.
[ ] Disclose any incentive as a material connection under Part 255 wherever the review is displayed.
[ ] Confirm no reviews were written by officers, employees, agents, or their relatives without conspicuous disclosure — § 465.5.
[ ] Confirm no fabricated, purchased, or AI-generated reviews exist anywhere in the ecosystem — § 465.2.
[ ] Audit the moderation policy: is it published, neutral, and applied identically to positive and negative reviews?
[ ] Confirm no practice suppresses negative reviews — verification queues, delayed posting, unfounded legal threats — § 465.7.
[ ] Confirm that any displayed subset of reviews is not presented as complete or representative if it is not.
[ ] Confirm aggregate star ratings are computed from the full eligible set and the methodology is accurate.
[ ] Confirm no company-controlled site is held out as independent — § 465.6.
[ ] Confirm no purchased followers, views, or engagement anywhere in the marketing stack — § 465.8.
[ ] Audit terms of service and warranty documents for non-disparagement clauses void under the Consumer Review Fairness Act, 15 U.S.C. § 45b.
[ ] Preserve review-platform logs, moderation decisions, and vendor contracts.

Why it matters, and the traps. Part 465 is a rule, so violations carry civil penalties per violation and support consumer redress — a materially different exposure than a guide. The trap is the well-intentioned "verification queue" that holds negative reviews for scrutiny while positive ones post instantly. That is asymmetric moderation, it is suppression, and it is usually documented in a workflow tool with timestamps. Ask the platform vendor for the moderation logs before a regulator does.

Phase 8 — Origin, Environmental, and Health Screens

[ ] For any U.S.-origin claim, confirm the product is "all or virtually all" made in the United States — 16 C.F.R. Part 323.
[ ] Trace the bill of materials and identify foreign content by value and by significance, not by count.
[ ] If the standard is not met, draft a qualified claim and place the qualification clearly, conspicuously, and proximately.
[ ] Check flag imagery, eagles, and "American" brand elements — they convey origin claims without words.
[ ] For environmental claims, reject unqualified general benefit claims ("green," "eco-friendly," "sustainable") and substitute a specific attribute.
[ ] For "recyclable," confirm facilities are available to a substantial majority of consumers where the product is sold — 16 C.F.R. Part 260.
[ ] For "compostable," "degradable," "carbon neutral," and offsets, apply the Green Guides' specific requirements and disclose timing and additionality.
[ ] Treat seals and certifications as endorsements: disclose the connection and the basis of certification.
[ ] Check the stricter state environmental marketing statutes, including chasing-arrows restrictions and carbon-claim disclosure laws.
[ ] For health claims, determine whether the claim is a disease claim converting the product into a drug.
[ ] For supplements, confirm structure/function notification, the DSHEA disclaimer, and substantiation.
[ ] Screen the whole campaign against the FTC Health Products Compliance Guidance.

Why it matters, and the traps. These three regimes share a trap: the claim is made by imagery and the compliance team only reviews text. A flag on the packaging is a Made in USA claim. A green leaf and a beige recycled-look substrate is an environmental claim. A photograph of a sleeping child beside a performance number is a health claim. Reviewing copy without reviewing art misses all three — and origin and review violations are the ones that carry per-violation penalties.

Phase 9 — Pricing, Offers, and Fees

[ ] For any reference price, confirm it was a bona fide price actually offered for a reasonably substantial period in the recent regular course of business — 16 C.F.R. Part 233.
[ ] Reject perpetual sale structures where the "sale" price is the only price ever charged.
[ ] For "compare at" claims, confirm the comparator is a comparable product actually sold at that price in the trade area.
[ ] For "free" offers, confirm the required purchase's regular price was not increased and quality not reduced — 16 C.F.R. Part 251.
[ ] Disclose all conditions of a free offer with the offer, not on a landing page.
[ ] Confirm the advertised item is available in reasonable quantity and that the sales floor is not steering to a higher-priced item — 16 C.F.R. Part 238.
[ ] Include all mandatory fees in the advertised total where a state statute or 16 C.F.R. Part 464 requires it.
[ ] Confirm no fee is introduced late in checkout that was not disclosed with the price.
[ ] Confirm shipping timing representations satisfy the 30-day rule, 16 C.F.R. Part 435.
[ ] Confirm financing, "0% APR," and installment claims satisfy the applicable consumer credit disclosure rules.
[ ] Retain pricing history in an exportable form tied to dates and channels.

Why it matters, and the traps. Reference-price cases are easy for plaintiffs because the proof is in the client's own pricing system: a query showing the "list price" was never charged decides the case. The second trap is drip pricing, where state law has moved well past the federal rule and now requires mandatory charges in the advertised price. Build one compliant price display and use it nationally; jurisdiction-specific pricing surfaces do not survive contact with a promotions calendar.

Phase 10 — Subscription and Negative Option Flows

[ ] Map the entire flow with screenshots: landing page, offer page, cart, consent, confirmation, first bill, cancellation.
[ ] Confirm all material terms — renewal, amount, frequency, cancellation deadline, and mechanism — appear before billing information is collected.
[ ] Confirm those terms are in visual proximity to the consent mechanism, not in a footer or a linked document.
[ ] Confirm consent to the negative option is separate and affirmative; eliminate pre-checked boxes and bundled consent.
[ ] Capture and store evidence of consent — the exact screen, the timestamp, and the terms as displayed.
[ ] Send a post-purchase acknowledgment restating the terms and the cancellation method.
[ ] Calendar advance renewal reminders required by state statutes and by the free-trial conversion rules.
[ ] Provide cancellation in the same medium as enrollment — online enrollment requires online cancellation.
[ ] Count the clicks: if enrolling takes two and cancelling takes six, the flow is a dark pattern.
[ ] Remove retention interstitials that obstruct rather than offer, and confirm any save offer can be declined in one action.
[ ] Confirm material change notices precede any price or term change.
[ ] Clear the flow against the strictest state auto-renewal statute, not the federal baseline.
[ ] Test the cancellation path monthly as an ordinary consumer and document the result.

Why it matters, and the traps. ROSCA's three requirements — disclose before billing, obtain express informed consent, provide a simple cancellation mechanism — map exactly onto the three things growth teams optimize away. The trap of the moment is misreading the Eighth Circuit's vacatur of the amended Negative Option Rule in Custom Communications, Inc. v. FTC, No. 24-3137 (8th Cir. July 8, 2025), as deregulation. ROSCA, Section 5, and every state statute survived. Nothing about compliant design changed.

Phase 11 — Sign-Off, Records, and Post-Launch Monitoring

[ ] Produce a final claims matrix: claim as consumers read it, claim type, evidence cited to page, gap analysis, disclosure text and placement, approver, and date.
[ ] Obtain written sign-off from the accountable business owner as well as counsel.
[ ] Archive the rendered assets in every format and aspect ratio, with disclosures visible.
[ ] Archive the substantiation itself — full protocols and data, not summaries.
[ ] Archive influencer agreements, claim sheets, training acknowledgments, and monitoring records.
[ ] Archive pricing history, review-moderation logs, and consent screens.
[ ] Set expiration dates on time-limited claims (#1, best-selling, award references, seasonal pricing) and calendar the review.
[ ] Re-clear any material creative change, including new cut-downs and new placements.
[ ] Monitor consumer complaints and social channels for evidence that the ad is being misunderstood — that is early notice of an implied claim.
[ ] Monitor competitor advertising for claims worth challenging, and for retaliation risk before you challenge.
[ ] Retain everything for the limitations period of the strictest applicable statute plus the campaign's tail.
[ ] Debrief after launch: which claims required deletion, and why did they reach legal review at all?

Why it matters, and the traps. Records are the defense. The Commission, NAD, and every plaintiff will ask what the advertiser possessed and when, and a well-organized dated file converts an existential problem into a manageable one. The trap is retention drift — agencies dissolve relationships, influencer platforms purge data, and review vendors rotate logs on a ninety-day cycle. Take custody of the records yourself at launch. You will not be able to reconstruct them two years later, which is exactly when you will need them.

Phase 12 — When a Challenge Arrives

[ ] Issue a litigation hold immediately, covering agency, lab, influencer platform, and review vendor records.
[ ] Identify the forum — FTC civil investigative demand, NAD challenge, Lanham Act demand or complaint, state attorney general inquiry, or class action — because each demands a different response.
[ ] Calendar the deadline. NAD requires substantiation within a short window, typically fifteen business days, and extensions are limited.
[ ] Pull the claims matrix and confirm the file matches what was actually disseminated.
[ ] Assess whether any challenged claim should be discontinued immediately to limit exposure and mootness arguments.
[ ] For an FTC CID, negotiate scope and timing early and preserve objections; do not narrow unilaterally.
[ ] For a Lanham Act demand, assess standing under Lexmark, literal versus implied falsity, and whether a survey exists or must be commissioned.
[ ] Consider whether an NAD challenge is a better forum than litigation — for either side.
[ ] Assess penalty exposure separately: rule violations under Parts 465, 323, 425, and 464 carry civil penalties; guide violations do not.
[ ] Assess individual and agency liability and whether separate counsel is required.
[ ] Evaluate corrective action — modified claims, disclosure changes, refund programs — as both mitigation and negotiation currency.
[ ] Treat a penalty offense notice as an urgent compliance project, not correspondence.

Why it matters, and the traps. The first seventy-two hours set the posture. The dominant trap is assembling substantiation after the demand and presenting it as if it had existed all along — which is a fraud on the agency and converts a civil matter into something worse. The second is treating an NAD challenge as low stakes because there are no damages. NAD produces a published decision, a referral risk, and a factual record your class-action adversary will quote in the complaint.

Worked Example

Halcyon Home Goods, Inc. (fictional) prepares to launch the AuraPure 3, a $399 air purifier, with an auto-renewing filter subscription, through its agency Quill & Ember (fictional). Its competitor is Meridian Air Systems, LLC (fictional); its testing lab is Brightline Testing Laboratories (fictional); its lead creator is Devon Ashcroft (fictional).

Phase 1. Counsel receives 41 assets across nine formats, plus a seeding list of 60 creators. Launch is in five weeks. Halcyon received an FTC penalty offense notice on endorsements eighteen months earlier, which nobody had mentioned.

Phase 2. The inventory captures nine express claims and, critically, four implied claims: that the unit removes 99.97% of allergens in a room; that it delivers a respiratory health benefit (from the sleeping-child image beside the number); that it outperforms Meridian (from a comparison chart under a superlative); and that it is domestically manufactured (from a flag on the packaging).

Phase 3. Brightline's chamber test supports filter media efficiency of 99.97% at 0.3 microns in a single pass at maximum fan speed — not whole-room performance. Its user study is 42 people, unblinded, single-arm, self-reported. Counsel rewrites the efficiency claim to state what was measured and deletes "clinically proven." Cost: one meeting.

Phase 4. The superlative sits above a comparison chart, so it is not puffery. Halcyon has no head-to-head data at consumer settings. The chart is pulled and the superlative moved to a page with no comparative content.

Phase 5. The fifteen-second vertical cut carries the subscription disclosure for 0.8 seconds in 11-point type. It is rebuilt with a four-second on-screen disclosure and a voiceover.

Phase 6. Devon Ashcroft's draft says "I've been using this for years." The relationship is eleven weeks old. The line is cut, the disclosure moves to the first caption line and a superimposed on-screen tag, and all 60 creators receive an approved claim sheet plus training, with acknowledgments retained.

Phase 7. The audit finds 900 reviews solicited with a $15 gift card conditioned on four stars or better, a verification queue holding one- and two-star submissions, and eleven reviews by service staff. All three practices stop. The incentive is decoupled from sentiment and disclosed; the queue is made symmetric; the staff reviews are removed and logged.

Phase 8. The bill of materials shows an imported motor and imported HEPA media. The flag comes off and the claim becomes "Assembled in Ohio from U.S. and imported components."

Phase 9. The $799 "list price" was live for nine days and never charged. It is removed; the product launches at $399 with no reference price.

Phase 10. The checkout pre-checks subscription enrollment, discloses $34/month below the purchase button, and routes cancellation to a weekday phone line. It is rebuilt: unchecked box, terms adjacent to the consent control, confirmation email, day-23 reminder before the trial converts, and online cancellation in two clicks.

Phase 11. The claims matrix is signed nine days before launch. Rendered assets, protocols, agreements, pricing history, and moderation logs are archived under Halcyon's control.

The outcome. Meridian files a SWIFT challenge on the comparative claim eleven weeks after launch. Halcyon produces the matrix and the protocol in nine days; NAD finds the revised claim adequately supported and recommends one wording change to the efficiency claim, which Halcyon adopts. No FTC action follows. No class action is filed.

What made it work: inventorying implied claims rather than express ones, reading the lab protocol instead of the summary, deleting one adverb that would have converted a marketing line into an evidentiary promise, decoupling review incentives from sentiment before anyone asked, and rebuilding the cancellation flow to the strictest state standard rather than the federal floor.

Clearing an Advertising Campaign: A Substantiation and Disclosure Checklist

Phase 1 — Intake and Scoping

Phase 2 — Building the Claim Inventory

Phase 3 — Substantiation Review

Phase 4 — Puffery, Comparative, and Superiority Claims

Phase 5 — Disclosure Design

Phase 6 — Endorsers, Influencers, and Employee Advocacy

Phase 7 — Reviews, Ratings, and Social Proof

Phase 8 — Origin, Environmental, and Health Screens

Phase 9 — Pricing, Offers, and Fees

Phase 10 — Subscription and Negative Option Flows

Phase 11 — Sign-Off, Records, and Post-Launch Monitoring

Phase 12 — When a Challenge Arrives

Worked Example

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