FTC endorsement rules set the closest US disclosure standard

The picture

The Federal Trade Commission's Guides Concerning the Use of Endorsements and Testimonials in Advertising, codified at 16 CFR Part 255, were most recently revised effective 26 July 2023, per the Federal Register citation carried in the regulation's own source note (88 FR 48102). The Guides are the FTC's administrative interpretation of Section 5 of the FTC Act as it applies to endorsements, and they set the general disclosure standard the agency applies when a marketing claim, including a depicted result, might not match a consumer's actual experience.

What the documents show

The regulation's own current text, read directly at the eCFR, states in section 255.1(a) that 'an endorsement may not convey any express or implied representation that would be deceptive if made directly by the advertiser', and section 255.2(b) requires that, where an endorser's result is not representative of what consumers will generally achieve, the advertisement must 'clearly and conspicuously disclose the generally expected performance in the depicted circumstances'. The FTC's own plain-language guidance, 'Endorsement Guides: What People Are Asking', confirms the Guides 'were revised in 2023 with new or revised principles, examples, and definitions, including a new definition of clearly and conspicuously', corroborating the eCFR's own revision date.

What it is allowed to decide

Part 255 is written for endorsements and testimonials, not for rendered images generally, and this entry does not stretch it into a CGI-specific rule the text does not state. What it does establish, read as a general principle, is the closest existing US regulatory analogue to a disclosure-label requirement: a depicted claim, of any kind, must not create an impression the advertiser could not lawfully make directly. Applied by analogy, this supports Class 3 Commercial disclosure obligations for any depicted product result; it holds no authority specific to Dimensional, Optical or Photometric accuracy of a render, since the Guides do not address rendering technique at all.

The disclosure label

Labelled here: a living federal regulation, last revised 26 July 2023; Auditability held, since its text and revision history are published in the Federal Register and the eCFR; Dimensional and Photometric authority not held, and not applicable, since the Guides govern endorsement claims generally rather than any rendering method. Dated 16 September 2026, this reading would be asserted by an advertising-law compliance officer applying an existing rule to a new medium, not by the FTC extending its own text.

• Would a rendered 'expected result' image fall under 255.2(b)'s disclosure requirement the way a testimonial photo does?
• What would 'clearly and conspicuously' mean applied to a disclosure label on a previs or CGI image rather than an endorsement?
• Does an advertiser's own depicted claim, without any named endorser, still fall under Section 5 the way 255.1(a) states?

No US rule requires a disclosure label on a rendered image the way this site proposes one; the Endorsement Guides show the closest existing analogue, applied here by extension rather than by the text's own terms.