What is a material connection?
A material connection is the FTC’s term for a relationship between an endorser and a brand that could affect how the audience weighs the endorsement, such as payment, employment, free products or a personal or family tie. Where one exists, it must be clearly disclosed.
Also known as: Endorser relationship, 实质关联
“Material connection” comes from the US Federal Trade Commission’s Guides Concerning the Use of Endorsements and Testimonials in Advertising (16 CFR Part 255), last revised in 2023.1 It decides one thing: whether an endorsement has to tell the audience about an interest behind it. In Chinese it is rendered 实质关联 (shízhì guānlián).
Which relationships count as a material connection?
The FTC’s Disclosures 101 for Social Media Influencers says that any financial, employment, personal or family relationship with a brand must be disclosed, and that free or discounted products count too.2
Canada’s Competition Bureau expects much the same of influencers: money, commissions, free products, discounts, trips, tickets and personal or family relationships are all to be disclosed.3
How must a material connection be disclosed?
The FTC wants the disclosure in the endorsement itself, not only in a profile or bio.2 The detailed labeling rules for sponsored content in China, the US and Canada are set out in how a sponsored post must be labeled.
Further reading
- How brand deals are sourced and vetted: Partnerships & opportunities
Notes
- Guides Concerning the Use of Endorsements and Testimonials in Advertising
- Disclosures 101 for Social Media Influencers
- Influencer marketing and the Competition Act