Model on the catwalkKimhekim show, Runway, Spring Summer 2020, Paris Fashion Week, France - 23 Sep 2019

After issuing a new guide on how influencers should disclose partnerships, the Federal Trade Commission is seeking public comment.

The FTC announced yesterday that it is looking for feedback on whether to modify its endorsement guidelines, which were enacted in 1980 and haven’t been updated since 2009. In a proposed Federal Register notice, the FTC is soliciting comments as part of a “systematic review” of its regulations and guides.

Among the FTC’s concerns are “whether changes in technology or the economy require changes to the guides” and “whether children are capable of understanding disclosures of material connections and how those disclosures might affect children.” These concerns seem to be somewhat related to the rise of TikTok, which is understood to have a large Gen Z audience and does have advertising capabilities.

The FTC also has questions regarding how well advertisers and influencers are disclosing their partnerships on social media and reviews based on incentives. In October, the FTC banned skin-care brand Sunday Riley from leaving fake reviews on its products.

The notice will be published in the Federal Register “soon” and includes instructions for filing comments. Comments, writes the FTC, must be received within 60 days of publication and will be posted publicly on

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