Website representations

Audit the testimonials and reviews on your storefront

Start by separating two things: genuine customer quotations the merchant selects or reuses for marketing, and an ordinary review-hosting function that displays customer feedback. The first is advertising the merchant chose; the second is a hosting function with its own honest-handling duties. Inventory each displayed item: who authored it, what it claims, whether the business has support for that claim, and what handling it receives. Act on claims the business cannot support, keep aggregates accurate, and publish a consistent moderation policy. Where classification is uncertain, ask counsel or the provider rather than guessing.

For: A research-only merchant that displays testimonials, star ratings, or customer reviews anywhere on the storefront.

Updated 2026-09-28

Marketing use and review hosting are different jobs

A testimonial the merchant picks for a banner, a product page, or an email is advertising the merchant chose to run. Genuine customer quotations selected for marketing carry the same substantiation duty as the store's own copy, plus disclosure of any relationship a reader would not expect. Business-authored ad copy in quotation marks is a different thing again: it is simply the store's own claim, and presenting invented text as a customer testimonial is not a category this page recognizes.

Distinguish ordinary review hosting from quotations selected for an advertisement. Record how reviews are collected, selected, moderated, and displayed, and whether the displayed set and its aggregate accurately represent the feedback. These facts inform a qualified assessment; this worksheet does not decide liability.

What the FTC's endorsement guidance actually says

The FTC's Endorsement Guides Q&A says endorsements must be honest and not misleading, that an endorsement cannot be used to make a claim the advertiser could not lawfully make itself, and that a material relationship a reader would not expect, such as payment, free product, or employment, can require a clear disclosure.

The same Q&A says it is not a safe harbor and that application depends on the actual facts. It supports checking that endorsements are truthful and that material connections are disclosed; it is not a universal liability finding about every displayed review. This page does not decide that a particular testimonial or review violates anything. Questions about whether a specific display complies with the law belong to qualified counsel.

Find the claims your product pages would not make

Read each displayed testimonial and review for its factual claim, not its sentiment. On a research-only merchant's storefront, the claims that matter most are human-use and outcome statements: a review describing personal use, dosing, or a physical result. Those are claims the store's own pages do not make, and a testimonial the merchant selects for marketing cannot carry a claim the merchant could not make itself.

Also look for factual conflicts with the catalog: a testimonial contradicting a documented product fact or asserting an unsupported result, a rating summary that does not match the reviews beneath it, a quote presented as current for a product the store no longer sells. Record each conflict with the URL of the display and the wording. Do not rewrite a customer's words into a stronger or safer claim; the honest options are accurate reproduction with context, disclosure of the relationship, or not selecting that quotation for marketing.

Handle hosted reviews honestly

For the hosting function, the durable answer is a published moderation policy applied consistently: what may be removed and why, who decides, and how disputes are handled. Genuine reviews should stay genuine — do not delete a review simply because it is negative or unfavorable, and do not inflate the displayed set with content that is not real customer feedback.

Keep the aggregates accurate. A star average, a count, or a distribution that does not match the underlying reviews is the store's own false statement, whatever any single review says. Content that is ineligible under the published policy — spam, abuse, or posts that are not real reviews — should be handled transparently under that policy, not silently curated into a more flattering picture. Where you are unsure whether an item is a review, an endorsement, or something the law treats specially, record the question and ask counsel rather than improvising a category.

Keep the inventory honest, including about its own limits

Act on what the inventory shows: stop selecting an unsupported quotation for marketing, add the missing disclosure, correct the aggregate, or handle the ineligible item under the published policy. Record who made each change and when it went live.

Date the inventory and name its owner, and be honest about the limits of both: new reviews arrive, widgets update, and a dated inventory can itself go stale, so set the next review date while you are in here. What none of this settles is legality or eligibility: a well-handled review section is not a legal finding and not a provider's approval. Prism's published review covers marketing claims, including testimonials and linked content, within an agreed scope, with findings that are informational.

Public claim, source, and handling inventory

One row per displayed testimonial or review surface. Record what is actually shown, who authored it, and how it is handled. Do not paste full customer names or private messages.

Worksheet entries are not submitted by Prism’s worksheet and are not saved by the site. Use record types, availability, anonymized observations, or match/mismatch results. Do not enter government identifiers, customer names or addresses, customer messages, receipt-access links, card or bank details, passwords, or keys. Send sensitive documents only through the provider’s verified secure channel.

Public claim, source, and handling inventory. The last column is for temporary notes.
Displayed item and locationAuthorship and the claim it makesSupport, relationship, and handlingYour note
Customer quotation selected for marketingA genuine customer's words the merchant chose for a banner, page, or campaign. Quote the claim, not just the praise.The same substantiation as the store's own copy, plus disclosure of any payment, free product, or employment a reader would not expect.
Business-authored copy presented as a quoteAd copy in quotation marks with no genuine customer behind it.Not a testimonial at all — the store's own claim. Presenting invented text as a customer's words is a finding, not a category.
Hosted user reviewA customer's words in the store's review section. Quote any human-use or outcome statement.Whether the claim matches what the listing and the store can support, and how the published moderation policy treats it.
Star rating or review summaryThe aggregate shown: average, count, distribution.Whether the summary matches the underlying reviews. A mismatch is the store's own false statement.
Third-party review widgetThe service and what it displays on the storefront.The settings the store controls and whether the displayed set is honest. Configuration is not concealment.
Collection and moderation policyHow items are gathered and what the published policy allows: organic, invited, incentivized.Unknown is an honest entry. An incentive a reader would not expect is a disclosure question for counsel, and the policy should be public and consistently applied.
Action and ownerDisclose, correct, stop selecting, or handle under policy, with the person's name and the next review date.The date the change was public. A dated inventory can also go stale; the next review date keeps it honest.

These are temporary notes. Leaving or reloading this page may clear them. Worksheet entries are not sent automatically. If you copy notes into the consultation message and submit the form, Prism receives them as part of your request.

Limits

  • Do not rewrite a customer's words into a stronger or safer claim, do not fabricate testimonials or reviews, do not delete reviews merely because they are negative, and do not hide a material relationship the reader would not expect.
  • The FTC's Q&A supports truthful endorsements and material-connection limits; it is not a safe harbor and not a universal liability finding. This page does not decide that a particular display violates the law — that question belongs to qualified counsel.
  • A well-handled review section does not establish eligibility or legal status. Account decisions belong to the provider.

Sources

  • FTC Endorsement Guides: What People Are Asking — checked 2026-09-28. Endorsements must be honest and not misleading; an endorsement cannot make a claim the advertiser could not lawfully make itself; unexpected material relationships can require clear disclosures; the Q&A is not a safe harbor and application depends on the actual facts.
  • FTC truth in advertising — checked 2026-09-28. Advertising must be truthful and not misleading, with appropriate substantiation, across media including the web; the guidance is not evidence that a specific phrase is lawful.
  • Prism features — checked 2026-09-28. A review can cover marketing claims including testimonials and linked content, within an agreed scope. Findings are informational, not a legal opinion or compliance certification, and do not guarantee approval or continued processing.
  • Prism contact — checked 2026-09-21. The form collects the website, products, and question. The request does not book an appointment, purchase a service, or submit a processing application; scope, fees, and terms are discussed before work.

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