Following NAD Inquiry, P&G Modifies Material Connection Disclosures in Influencer TikTok Videos to Ensure They Appear on Other Platforms When Shared

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New York, NY – September 10, 2020 – Following an inquiry by the National Advertising Division (NAD) of BBB National Programs, The Procter & Gamble Company (P&G) took steps to ensure that its influencers, who promote its Bounty Paper towels in a series of catchy TikTok videos, embed material connection disclosures in the videos to ensure that clear and conspicuous disclosure appears on any platform where they are shared.   

The videos featured a “dance challenge” in which the influencers break out into a dance while the high-pitched voiceover sings about how it’s time to “clean up your life.” Bounty paper towels appeared in the background and all of the TikTok videos clearly and conspicuously include the hashtag #BountyPartner disclosing the material connection between the influencer and P&G in accordance with FTC guidelines.   

However, when those videos were shared to Instagram, they did not include the #BountyPartner hashtag indicating the paid partnership between P&G and the influencer (but the disclosure did appear when the videos were shared to other platforms - e.g., Facebook). NAD was concerned that consumers seeing the TikTok videos in question on Instagram would not understand that these were paid advertisements.  

P&G was apprised of this issue prior to the challenge and immediately began requiring that influencers embed disclosures in their videos so that disclosures would transfer along with the videos when shared across platforms, and provided examples of such videos. P&G also undertook an internal audit on all associated Bounty content for this campaign and will ensure that all new Bounty TikTok content has embedded disclosures. However, existing TikTok posts could not be edited and reposted due to TikTok’s terms and influencers’ contractual limitations.   

In its advertiser’s statement, P&G stated that it was “pleased that NAD agrees that P&G’s efforts to disclose its material connection with influencers was deemed sufficient” and “values the self-regulatory forum provided by NAD and appreciates the professionalism and commitment shown by NAD in the resolution of this matter.”  

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About BBB National Programs: BBB National Programs is where businesses turn to enhance consumer trust and consumers are heard. The non-profit organization creates a fairer playing field for businesses and a better experience for consumers through the development and delivery of effective third-party accountability and dispute resolution programs. Embracing its role as an independent organization since the restructuring of the Council of Better Business Bureaus in June 2019, BBB National Programs today oversees more than a dozen leading national industry self-regulation programs, and continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-directed marketing, and privacy. To learn more, visit bbbprograms.org. 

About the National Advertising Division: The National Advertising Division (NAD), a division of BBB National Programs, provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. NAD reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.