Between 2021 and 2026 the US, the EU and the UK each wrote specific rules for reviews, origin and green claims. Here is what each says, and from when.
Review and claim rules used to say only: don’t deceive. Now they name specific practices and set penalties per violation. This is a dated map as of September 2026, not legal advice; have counsel review your practices against it.
| Rule | Date | What it means for a brand |
|---|---|---|
| FTC Rule on the Use of Consumer Reviews and Testimonials (16 CFR Part 465) | Announced Aug 14, 2024; effective Oct 21, 2024 | Bans fake reviews and testimonials, including AI-generated ones; buying reviews conditioned on sentiment; undisclosed reviews by officers and employees; company-controlled review sites posing as independent; suppressing reviews by unfounded legal threats or intimidation, or implying you show most or all reviews when you’ve suppressed negative ones; and buying fake followers or views. Civil penalties for knowing violations. |
| FTC Endorsement Guides, revised | Approved June 29, 2023 | Don’t procure, suppress, boost, organize or edit reviews in a way that distorts what customers think. Disclose material connections with reviewers and endorsers. |
| Consumer Review Fairness Act | 2016 | Form contracts can’t bar honest reviews, fine customers for them, or claim rights in the review’s content. |
| Made in USA Labeling Rule (16 CFR Part 323) | Effective Aug 13, 2021 | Unqualified US-origin claims on labels and mail-order material must meet the “all or virtually all” standard. Civil penalties. |
| Green Guides (16 CFR Part 260) | Last revised 2012; review opened Dec 2022 | Guidance on “recyclable,” “compostable,” “eco” and similar terms. Still the 2012 version as of September 2026. |
| Health Products Compliance Guidance | Dec 2022 | Health claims need competent and reliable scientific evidence, generally randomized controlled trials. Testimonials don’t substitute. |
PublishedFTC, Federal Register and eCFR texts listed in Appendix C. Green Guides status: no revision in the Federal Register, and none listed by the BWD Strategic tracker, checked September 2026.
The review rule has started to bite. On December 22, 2025, the FTC sent warning letters to ten companies about possible violations, noting penalties of up to $53,088 per violation Filed. That is the 2025 inflation-adjusted cap; the Federal Register showed no 2026 adjustment as of September 2026 Published. Before the rule, in October 2021, it had already sent a Notice of Penalty Offenses on endorsements to more than 700 companies, which makes it easier to seek civil penalties from recipients who later use those practices Filed.
If you sell into the EU, act on the green claims rules now: “carbon neutral shipping” backed by offsets is exactly what the new list bans. A separate EU proposal on substantiating green claims is a different law; ask counsel where it stands.
The Digital Markets, Competition and Consumers Act 2024 lists practices that are unfair in all circumstances, including submitting or commissioning fake reviews, concealing that a review was incentivized, and publishing reviews or review information in a misleading way. Those provisions came into force on April 6, 2025 Published. The Competition and Markets Authority’s guidance, published two days earlier, says businesses that publish reviews must take “reasonable and proportionate steps” to prevent and remove banned content, may use incentives only if the review says so and still reflects a real experience, and must not suppress genuine negative or positive reviews Published. Penalties under the Act can reach £300,000 or 10% of turnover, whichever is higher, and the CMA can now impose fines itself instead of going to court Published.
The question used to be whether a practice was deceptive. Now it’s often whether it’s on a list.
Green claims get enforced too. In January 2022, Keurig Canada agreed to pay a C$3 million penalty to settle the Canadian Competition Bureau’s concerns about its K-Cup pods. The Bureau found that recyclability claims were false or misleading, because municipal recycling programs outside British Columbia and Quebec didn’t accept the pods, and that the instructions for preparing them for recycling didn’t match what many municipalities required. Keurig also donated C$800,000 to an environmental charity, paid C$85,000 in costs, changed its packaging claims and published corrective notices, including to its subscribers by email Filed.
The claim was one word on the box. The evidence it needed was a map of where the pod could be recycled. That’s the “what the evidence supports” column, filled in by a regulator.
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.