# What claims can I make in an ad? FTC and ASA basics

> US and UK basics read 17 Oct 2026: have proof before the ad runs, watch implied claims, never invent reviews, and treat superlatives as claims. Checklist inside.

Source: https://singingads.com/guides/ad-claims-rules-small-business

# What claims can a small business make in an ad?

In the US and the UK the core rule is the same: you must be able to prove what your ad says, or implies, before it runs. The FTC asks for a reasonable basis, and scientific evidence for health and safety claims; the UK CAP Code asks for documentary evidence first. Fake reviews are banned in both. Obvious puffery is fine; specific numbers need proof.

Updated 17 Oct 2026

## United States: the FTC basics

The FTC's guide for small business sets out three rules: ads must be truthful and not deceptive, advertisers must have evidence to back up their claims, and ads cannot be unfair. It looks at the whole ad as a reasonable consumer would, including **implied** claims: "kills the germs that cause colds" implies "prevents colds", and you need proof for that. Proof must exist before the ad runs. Health and safety claims need competent and reliable scientific evidence, and letters from satisfied customers do not count as proof. Ad agencies can be held responsible too.

Since 21 October 2024, the FTC's rule on consumer reviews and testimonials targets fake or false reviews and testimonials, with civil penalties for knowing violations.

## United Kingdom: the CAP Code basics

The ASA enforces the CAP Code. Its misleading advertising section says ads must not materially mislead (rule 3.1), must not leave out material information (3.3), and that marketers must hold documentary evidence for objective claims before publishing (3.7). Obvious exaggeration that no one takes literally is allowed (3.2). Unqualified superlatives are treated as comparisons against every competitor and need evidence unless they are clear puffery. Fake consumer reviews are banned (3.44), incentivised reviews must be flagged (3.45), and you need proof a testimonial is genuine (3.47).

## Platform rules sit on top

The platforms add their own layer. TikTok's ad policy (April 2026) bans promising or exaggerating results, absolute claims about time, region or brand, before-and-after result comparisons, and any mismatch between the ad and the landing page on price, discount or promotion. Its own example: an ad saying "up to 50% off" while the site says "up to 30% off" is not allowed.

## A sung claim is still a claim

Music makes words feel lighter, not legally lighter. "The softest towel you'll ever own" in a chorus is a superlative claim. "Clears skin in a week" sung sweetly is a health and result claim. Before you approve lyrics, read them as if they were printed in the caption. SingingAds copies every claim from words on your page and flags health, money, result and comparison claims for you to check; see [claims from your page](https://singingads.com/features/ad-claims-from-your-page).

## A five-minute pre-flight check

- Underline every factual claim, spoken, sung or on screen.
- Next to each, write where the proof is (a test, a spec sheet, a supplier certificate).
- Check that prices and offers match the landing page exactly.
- Delete any review or quote you cannot trace to a real customer.
- Ask: what would a reasonable buyer assume from this that I have not said?

This is general information, not legal advice. For regulated products, ask a lawyer. Related reading: [AI label rules](https://singingads.com/guides/ai-label-rules-for-ads) and [how SingingAds builds a brief](https://singingads.com/how-it-works).

## Illustrative example: auditing a product page before writing lyrics

**Product:** Saltmarsh Skin Balm (fictional). Lines on its page and what can be sung:

- "Made with shea butter and beeswax": a fact about ingredients. Fine to sing.
- "50 ml tin, ships in two days": a checkable fact. Fine, if true at the time of the ad.
- "Heals eczema": a health claim needing scientific evidence. Leave it out.
- "Britain's favourite balm": an unqualified superlative. Leave it out or replace it with something you can show.
- "Loved by 10,000 customers": a number you must be able to prove. Leave it out unless you can.

Sung line that survives: "Shea and beeswax, tin in your bag, Saltmarsh."

## The options

- ### Objective product facts Size, ingredients, materials and delivery times are easy to prove and safe to sing. Best for

Every product ad.

Price

No cost

- ### Health and safety claims The FTC expects competent and reliable scientific evidence; the ASA expects documentary proof first. Best for

Skincare, supplements, fitness, baby products.

Price

Varies: testing can be costly

- ### Result and performance claims TikTok bans exaggerated results and before-and-after comparisons; both regulators want proof. Best for

Cleaning, beauty and gadget ads.

Price

Varies

- ### Superlatives and ranked-first claims The ASA treats unqualified superlatives as comparisons with every rival; TikTok bans absolute brand claims. Best for

Anyone tempted to say "the softest" or "the top".

Price

No cost to leave out

- ### Comparisons with competitors Must compare like with like on verifiable features; never denigrate the rival. Best for

Challenger brands.

Price

No cost, but keep the evidence

- ### Prices and discounts Must match the landing page and not mislead about savings. Best for

Sales, Black Friday and launch offers.

Price

No cost

- ### Reviews and testimonials Fake reviews are banned in the US and UK; you need proof a testimonial is real. Best for

Ads quoting customers.

Price

No cost

- ### Implied claims The FTC judges what a reasonable buyer takes away, not only the literal words. Best for

Clever wordplay in lyrics.

Price

No cost

- ### Puffery Obvious exaggeration no one takes literally is allowed in both countries. Best for

Fun brand tone ("sunshine in a jar").

Price

No cost

- ### Material omissions Leaving out key limits (subscription terms, delivery fees) can mislead as much as a false claim. Best for

Offers with conditions.

Price

No cost

## What it can’t do

- This is a summary of public guidance, not legal advice.
- Rules for regulated sectors (medicines, finance, alcohol, children) go further than this page.
- Covers the US and UK only; other countries have their own rules.

Paste your product page. SingingAds writes a jingle about it, sings it and cuts a vertical video ad, using only claims your page makes.

From $15 for one ad, or $59 for about 6 thirty-second video ads. Credits never expire. Made with AI; you approve every word before anything is sung.

## What it costs

From $15 for one ad, or $59 for about 6 thirty-second video ads. Credits never expire. A jingle take costs 4 credits; a typical 30-second video ad about 26. There is no free tier and no free sample.

One-time packs

### One ad

**$15** once

40 credits, about 1 thirty-second video ad

### Five ads

**$59** once

180 credits, about 6 thirty-second video ads

[Full pricing, credits and refunds](https://singingads.com/pricing)

## Questions

**Can I call my product the greatest or the softest?**

Vague puffery like "great taste" is usually fine. Specific superlatives ("the softest", "the top-selling") need evidence in the UK and can break TikTok's absolute-claims rule.

**Do customer reviews count as proof for a claim?**

Not for objective claims. The FTC says letters from satisfied customers are not enough to support a health or safety claim.

**Does the FTC check ads before they run?**

No. The FTC says its staff cannot clear ads in advance; it is up to you to have proof before launch.

**Can I use an AI-generated customer quote?**

Not as if it were real. A made-up testimonial presented as genuine is a fake review under both US and UK rules.

**Is my ad agency responsible too?**

It can be. The FTC says agencies may be liable for misleading claims and must check the substantiation themselves.

## Sources

- [US Federal Trade Commission, Advertising FAQ’s: A Guide for Small Business](https://www.ftc.gov/business-guidance/resources/advertising-faqs-guide-small-business), read 17 Oct 2026
- [US Federal Trade Commission, The Consumer Reviews and Testimonials Rule: Questions and Answers](https://www.ftc.gov/business-guidance/resources/consumer-reviews-testimonials-rule-questions-answers), read 17 Oct 2026
- [Advertising Standards Authority / CAP, CAP Code section 03: Misleading advertising](https://www.asa.org.uk/type/non_broadcast/code_section/03.html), read 17 Oct 2026
- [TikTok, Misleading and false content](https://ads.tiktok.com/help/article/tiktok-ads-policy-misleading-and-false-content?lang=en), 2026-04, read 17 Oct 2026

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- [AllGuides](https://singingads.com/guides)
