Find the kind of claim you’re making. The row tells you whether the customer can check it, what belongs in your file, and which rules apply.
The further down a claim sits, the less the customer can check it, and the more your reviews, your file and regulators have to say about it.
| Kind of claim | Can the buyer check it? | What goes in the file | Rules that bite (US, EU, UK) |
|---|---|---|---|
| Product facts: size, material, weight, count | Before buying, mostly | Spec sheet, supplier certificate, your own measurement | General deception law |
| Performance: lasts 12 hours, fits true to size | Only after use | Your test method and results, dated; return and review data | FTC substantiation policy (1984) |
| Social proof: 4.8 stars, 40,000 customers | Partly, by reading reviews | Review export, how the average is computed, order counts | FTC review rule (2024); EU review rules (2022); UK DMCC Act (2025) |
| Testimonials, influencers, expert quotes | No | Signed consent, any payment or free product, typicality evidence | FTC Endorsement Guides (2023); FTC review rule |
| Origin: Made in USA, made in Vermont | No | Bill of materials with country of each input, where each step happens | FTC Made in USA rule (2021) |
| Process: handmade, small batch, family owned | No | Who makes it, where, how, and the share done by hand | General deception law |
| Health and efficacy: clinically shown, supports sleep | No | Studies on your formula or its active doses, ideally randomized trials | FTC health products guidance (2022) |
| Environmental: recyclable, eco, carbon neutral | No | Certifications, recycling access data, emissions accounts | FTC Green Guides (2012); EU Directive 2024/825 from Sept 27, 2026 |
PublishedDates are when each rule or guide took effect or was last revised; chapter 11 has the details and sources. Economists have sorted claims this way since Phillip Nelson (1970) and Michael Darby and Edi Karni (1973): search qualities you can check before buying, experience qualities you learn by using, and credence qualities you may never be able to verify.
Most DTC brands put their strongest words in the bottom four rows, because that’s where the differentiation lives. Those are also the rows where customers depend most on your word, and where a regulator is most likely to ask for your file.
Your best claims are the ones customers can’t check. That’s why they need the best proof.
This is one chapter of The Proof File, which is free and readable in full on a single page with no form in front of it.