Website representations

What relationship supports an independently-tested statement?

Collect the genuine records behind the sentence before deciding what it can support: who the issuer is, what ownership or control connections exist between merchant and laboratory, who paid for the work and on what terms, who selected and supplied the samples, and what was actually tested. These are factors to test against the specific claim's implied meaning and any applicable standard or engagement terms; whether a given arrangement satisfies an independence claim is a qualified-assessment question, not a rule this page supplies. Keep the wording scoped to the work performed, record who selected samples factually without implying arrangements that did not occur, and where the records cannot establish the relationship either way, narrow or remove the unqualified claim.

For: A research-only merchant whose storefront, packaging or marketing describes products or batches as independently tested or verified by an outside laboratory.

Updated 2026-10-01

Decide what the sentence means by independent

'Independently tested' is a relationship claim, not a quality claim. Before checking any records, write down what a reader would take your sentence to mean: that an organization with no ownership or control connection to the merchant chose methods and reported results without the merchant directing the outcome. That implied meaning — not a universal definition, which this page does not supply — is what your evidence has to carry.

Copy the exact wording and placement, including badges and captions that add independence language the body text avoids. 'Third-party tested', 'independently verified' and 'outside laboratory confirmed' make overlapping but not identical assertions; a worksheet entry per phrase prevents a record that supports one from being stretched across all three.

Identify the issuer and the work actually performed

From the report itself and the engagement records, establish who issued the document, who commissioned it, what sample or lot it identifies, and what it measured. These are the attribution basics, and they come first because an independence claim about a misattributed report fails before relationships are even examined. Keep the issuer, the supplier who may have provided the file, and the merchant as three distinct parties until the records say otherwise.

Record the scope of the work precisely. A laboratory that tested one submitted sample of one batch performed that work; the independence statement on the page should not quietly extend to the whole catalog, every batch or ongoing production. Independence describes a relationship around a piece of work, and the claim inherits the work's limits as well as its credibility.

Examine ownership, funding and sample selection

Now assemble the relationship facts from genuine records: corporate or ownership connections between the merchant and the laboratory, shared principals or control arrangements, who paid for the testing and under what terms, and whether any fee depended on the outcome. These are the facts the claim's implied meaning is tested against. How much weight each fact carries, and whether a particular arrangement defeats an independence claim under the applicable standard or rules, is a judgment for qualified review — this checklist gathers the record; it does not decide independence universally. Commissioning and paying for testing is ordinary commerce, and neither payment alone nor any single factor here settles the question by itself.

Sample selection deserves its own line, recorded factually: who chose the tested sample, who supplied it, and whether the laboratory drew it or received it from the merchant. The wording on the page must match what actually occurred and must not describe laboratory-drawn sampling that did not happen. Where any of these questions cannot be answered from records, mark it unresolved rather than assuming the favorable answer.

FTC staff guidance on the Consumer Reviews and Testimonials Rule addresses, among other things, evaluations presented as independent when the business controlled them. That guidance concerns reviews rather than laboratory reports, but the underlying principle — that a false appearance of independence is deceptive — is the reason these relationship questions belong in the worksheet at all.

Keep independence separate from accreditation and accuracy

Three properties of a testing arrangement are routinely collapsed into one word. Independence is about the relationship between merchant and laboratory. Accreditation is about a laboratory's assessed competence against a standard such as ISO/IEC 17025, established by its own scope records. Accuracy is about whether the work was done and reported correctly, which this page does not evaluate. A laboratory can hold any one of these without the others, so no single document establishes the whole claim.

Check what each record you hold actually proves. An accreditation scope document says nothing about who owns the laboratory. An invoice showing arm's-length payment says nothing about competence. The independence worksheet stands beside the attribution and accreditation checks you may already run; it does not replace them, and passing those checks does not pass this one.

Choose wording the records can carry

Whatever the relationship record shows, the supported claim still belongs to the work performed: the identified issuer, the tested item or batch, and the property measured. Where the record shows a relationship a reader could find material, the options include disclosing it accurately in the same breath as the claim, or dropping the independence framing and stating the attributable fact: that a named laboratory issued a report for an identified batch. Disclosure is not an automatic cure; whether disclosed wording still misleads a reader is part of the same qualified assessment as the independence question itself.

The FTC's substantiation policy requires an objective claim's evidentiary basis to exist before publication; an independence claim's basis is the relationship record assembled here, and where that record is incomplete the unqualified claim rests on an assumption. Record the wording decision, the supporting references and the owner, and re-run the sheet when the laboratory, the engagement terms or the page layout changes.

For a Prism website-review consultation, bring the URLs carrying the independence language and a summary of the relationship evidence you hold; scope, responsibilities, fees and terms are agreed before work. The review examines the public representation within that scope. It does not investigate corporate records, judge laboratory quality or provide a legal conclusion, and no wording change establishes product legality or provider eligibility.

Independence evidence sheet

Complete one sheet per independence claim and testing relationship. Work from genuine engagement and relationship records, mark unresolved questions unresolved, and keep confidential documents as references rather than attachments. The sheet assembles the record; interpreting it against the applicable standard belongs with qualified review.

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.

Independence evidence sheet. The last column is for temporary notes.
Relationship elementGenuine record to checkYour finding
Exact claim and placementThe copied wording, URL and adjacent badges or captions, with the implied meaning of 'independent' written out.
Issuer and attributionThe report's printed issuer, identifier and dates, kept distinct from the supplier that provided the file.
Work performedThe engagement record identifying the sample or lot tested and the property measured, which bounds the claim.
Ownership and controlRecords establishing whether any ownership, shared-principal or control connection exists between merchant and laboratory — facts to be interpreted against the claim, not a self-deciding verdict.
Funding termsThe payment record and terms, recording factually whether fees were ordinary commerce or contingent on outcomes.
Sample selectionThe record of who chose and supplied the tested sample, so wording does not imply laboratory-drawn sampling that did not occur.
Material-relationship decisionWhether any relationship a reader would want disclosed exists, and the chosen disclosure or narrower wording, with interpretation confirmed by qualified review where the applicable standard is uncertain.
Separation from accreditationConfirmation that no accreditation, competence or accuracy record is being treated as evidence of independence, or vice versa.
Publication record and ownerThe final wording, evidence references, responsible editor and the change events that trigger re-review.

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

  • This page does not define laboratory independence universally; it tests the specific claim's implied meaning against the merchant's genuine records.
  • Independence, accreditation and result accuracy are separate properties; no single document or standard establishes all three, and this worksheet evaluates none of the science.
  • FTC reviews-rule staff guidance concerns reviews and testimonials; it is cited for the false-independence principle, not as a laboratory standard or a safe harbor.
  • Where relationship facts cannot be established, remove or narrow the claim rather than assuming the favorable answer; legal conclusions belong with qualified counsel.
  • A corrected statement does not establish product safety, legality or payment-provider eligibility.

Sources

  • FTC: Consumer Reviews and Testimonials Rule questions — checked 2026-10-01. FTC staff guidance addresses deceptive practices including evaluations presented as independent when controlled by the business. It concerns reviews and testimonials, not laboratories, and is not a safe harbor; it is cited here for the false-independence principle.
  • FTC: Advertising Substantiation Policy — checked 2026-10-01. Objective advertising claims need an appropriate evidentiary basis before publication, and claimed support must exist. An independence claim needs relationship records behind it; the policy is US advertising guidance.

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