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ASA and CAP Code · 10 min read

How to check advertising claims before launch: a checklist for marketing teams

A twelve-point checklist for marketing teams: how to check advertising claims, flag the risky ones and fix unverifiable wording before launch.

To check advertising claims before launch, go through the copy for every statement a customer could test, ask whether you could prove it today, and fix or remove what you can't. This checklist is for marketing teams under time pressure. Start by running the draft through the free advertising claim checker, which highlights the phrases that are claims, then work through the points below.

Why check advertising claims before launch

Once an ad is live, a complaint to the ASA, a competitor's challenge or a regulator's question needs an answer from evidence you already hold. The CAP Code (rule 3.7) expects that evidence before the ad goes out, and the FTC expects a reasonable basis at the time the claim is made. Checking in the last week before launch costs hours; withdrawing a campaign costs far more.

How to flag risky marketing claims

Some wording carries more risk than the rest. Flag these first, because they need the strongest proof or a rewrite:

  • Absolute words: best, fastest, guaranteed, 100%, never, always. The CAP Code treats exaggerating what a product can do as misleading (rule 3.11).
  • Comparisons with competitors: they must compare products that meet the same need, on features that can be checked (CAP Code rules 3.33 and 3.34).
  • Health and beauty results: clinically proven needs studies on people that support the exact result claimed.
  • Green wording: eco-friendly, sustainable, carbon neutral. Under the CAP Code, absolute environmental claims need a high level of substantiation (rule 11.3).
  • Claims without their conditions: a result that only holds in a test setting, a price that only applies to some customers.
  • Testimonials and reviews: a customer's words count as your claim, and you need the same proof.

The twelve kinds of marketing claim, and what each covers

Sorting claims by kind tells you what evidence to look for, because each kind needs different proof. These are the kinds the Claim Risk Checker uses:

  • Performance and specifications: what the product does, with a figure, such as removes 99% of airborne dust within 30 minutes.
  • Comparisons: better or cheaper than something else, including your own older models.
  • Superlatives: best, first, only or market-leading.
  • Health and beauty: clinical, skin, allergy or anti-ageing results.
  • Environmental: green, recyclable, carbon neutral or plastic-free.
  • Safety: safe, non-toxic or fire-resistant.
  • Certifications and standards: marks, standards and approvals.
  • Price and savings: prices, discounts and payback.
  • Origin: where it is made, and since when.
  • New and free: new, improved or free.
  • Popularity: trusted by, award-winning, customer counts.
  • Reviews and ratings: star ratings and review counts.

Opinion such as a design you will love, calls to action, menus and legal small print are not claims of any kind.

Who is speaking changes the proof

The same words need different proof depending on who says them:

  • The product: the default. You need evidence for the claim itself.
  • The company: founded in 1952, trusted by 200 manufacturers. You need records that show it, counted the way a reader would understand it.
  • A customer testimonial: you need proof the customer is real and agreed to be quoted, and if the quote promises a result, that the result is typical.
  • An endorsement: recommended by, award-winning, as seen on. Keep proof of it, and say if anything was given in return.
  • A third-party statistic: 9 out of 10 dentists. You need the survey: who was asked, how many, and the exact question.

What raises and lowers the risk of a claim

A claim's kind sets where its risk starts. High: health and beauty results, safety, superlatives, broad green wording, comparisons with competitors, and an unqualified Made in Britain or Made in USA. Medium: a specific claim that needs evidence on file, such as a performance figure, a certification, a rating, a customer count or a comparison with your own earlier product. Low: new, free, or a claim that already names its source, conditions or the part it covers.

The wording then moves it one level up or down:

  • Up: absolute words such as guaranteed, always, never, 100% or risk-free; an up to figure; a figure with no condition, source or footnote; a customer quote that promises a measurable or health result.
  • Down: a named source and a stated condition, such as in independent tests at 20°C; a footnote that names the test or source; a green claim limited to a specific part, such as a housing made from 30% recycled plastic.

Finding unverifiable marketing claims

Unverifiable claims in marketing copy sound factual but can't be checked: up to 10 times faster with no baseline, trusted by thousands with no count, industry-leading with no measure. These are the hardest to defend, because there is nothing to prove. Either make them specific and measurable, or turn them into clear opinion that nobody would read as a fact.

BeforeThe fastest way to clean your floors.After reviewCleans a 20 m² room in 12 minutes in our tests on hard floors.

The pre-launch checklist

Work through each point for every claim in the campaign.

  • List every claim, including those made by images, charts and the product name.
  • Write what a typical customer will take each claim to mean.
  • Confirm you hold the evidence now, not that you could get it.
  • Check the evidence tests the product as sold, under the conditions claimed.
  • Rewrite absolute words unless you can prove them in every case.
  • Name the comparator in any comparison, and compare like with like.
  • Put conditions and qualifications next to the claim.
  • Check testimonials are real, from real customers, and typical, or say they aren't.
  • Check green claims cover the whole product life cycle, or say which part.
  • Check each market's rules: the UK and the US differ.
  • Get sign-off from Legal and the function that owns the facts.
  • Record the decision, the evidence and a date to review it.

UK and US rules to know

UK: the CAP Code covers paid-for ads and marketing on your own website and in other online space you control; the DMCC Act 2024 gives the CMA direct powers over misleading practices, with fines of up to 10% of global turnover; the CMA's Green Claims Code sets six principles for environmental wording; and the Business Protection from Misleading Marketing Regulations 2008 cover advertising to businesses.

US: the FTC Act bans deceptive advertising, and the FTC's substantiation policy requires a reasonable basis for objective claims. The Green Guides cover environmental claims, the Endorsement Guides cover testimonials and influencers, and since 2024 the FTC's rule on consumer reviews (16 CFR Part 465) bans fake reviews and buying reviews that express a particular sentiment.

Within these, narrower tests apply:

  • CAP Code sections 11 and 12: environmental claims, and health and beauty claims, with their own evidence rules.
  • DMCC Act 2024: besides misleading practices, it bans fake reviews.
  • FTC Policy Statement on Deception (1983): what makes an ad deceptive.
  • FTC Health Products Compliance Guidance: health claims need competent and reliable scientific evidence.
  • Made in USA rule (16 CFR Part 323): Made in USA means all or virtually all of the product is made in the US.
  • Guide on ‘Free’ (16 CFR Part 251) and Guides Against Deceptive Pricing (16 CFR Part 233): a free offer must not hide costs or raise the price of what people pay for, and a was price must be a price you really charged.

After the check: keep the proof with the claim

A checklist done once, in someone's inbox, is hard to find six months later. Keep each claim with its evidence, the rules checked and the decision, so the next campaign can reuse what is approved. Veridat does this for each claim, with a checklist of the evidence it needs and sign-off by function: see how it works, or see the rules for green claims.

To compare the tools that help with each step, from free checkers to sign-off software, see our guide to the best tools for verifying advertising claims.

Before your next launch, flag the risky claims in your draft in a couple of minutes, free and with no account.

Questions

How do I check advertising claims quickly?
Start with the claims most likely to cause trouble: absolute words, comparisons, health and green wording, and anything with a number. For each, ask whether you hold the evidence today and whether it matches the wording exactly. A tool that highlights claims in your copy can find them faster, but the judgement on the evidence stays with you.

What makes a marketing claim risky?
A claim is risky when it promises more than your evidence shows, or when a rule sets a high bar for it. Absolute wording, comparisons with competitors, health benefits, environmental benefits and missing conditions all raise the risk. A named source, a stated test condition and a claim limited to a specific part of the product all lower it.

What is an unverifiable claim?
It is a statement that sounds like a fact but gives nothing to check, such as industry-leading or up to 10 times faster with no baseline. Customers may still take it as a fact, so you may still need to prove it. Make it specific and measurable, or reword it as an opinion nobody would read as fact.

Do these rules apply to social media and influencer posts?
Yes. The CAP Code covers paid-for online ads, marketing in online space you control, and content you pay someone to publish when you control it. In the US, the FTC's Endorsement Guides say you need the same proof for an endorser's claim as if you made it, and a material connection must be clearly disclosed.

Keep the proof and the sign-off with every claim.

Veridat builds a checklist of the evidence each claim needs, holds the proof against each item, and records who signed off and why. 14 days free, no card needed.

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This guide is for information only and is not legal advice. For decisions about specific claims, speak to a qualified adviser.

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