How to Write a Prohibited Claims List That Creators Understand
Managing influencer and affiliate marketing programs for e-commerce brands in regulated industries like hemp/CBD and health-adjacent products demands a clear, actionable prohibited claims list. If your program relies on third-party creators to share your product, you are ultimately responsible for the claims they make, including implied disease claims and health statements. Brands like Joy Organics and platforms such as Tomoson have paved the way with effective creator compliance approaches, guided by FTC (Federal Trade Commission) regulations and operational discipline including monitoring on major channels like Meta and Google.
Why Brand Responsibility for Creator Claims Is Critical
The FTC holds brands accountable for anything that third-party creators say or imply about https://stateofseo.com/how-to-make-sure-disclosures-are-readable-on-mobile/ their products. This includes direct claims (“This oil cures anxiety”) and implied disease claims (“Feel calm and anxiety-free with this oil”). Failure to control these claims can result in costly enforcement actions, brand reputation damage, and program shutdowns.

Having a clear, comprehensible prohibited claims list protects your brand and empowers creators to market your products confidently while staying compliant. But many brands stumble by producing vague or overly technical lists that confuse influencers instead of guiding them.

FTC Training and Monitoring Expectations
The FTC requires brands to:
- Train creators on what claims are allowed and prohibited
- Provide plain language examples
- Monitor creators’ posts and messaging (especially on platforms like Meta and Google)
- Take remedial action if prohibited claims occur
For example, Joy Organics, a leading CBD brand, regularly conducts creator workshops focusing on compliant language, especially highlighting how subtle wording can become implied disease claims. Monitoring and pilot audits of creators’ posts allow immediate feedback and content removal if necessary.
Pro Tip: Use tools like Tomoson to streamline creator onboarding and track post compliance automatically across social channels.
Approved vs Prohibited Language Lists: What’s the Difference?
Many brands confuse “approved” and “prohibited” language. Both are essential components of your compliance toolkit but serve different purposes:
Aspect Approved Language Prohibited Language Purpose Specifies claims creators are allowed to make Specifies claims creators must NOT make Examples "Supports general wellness," "Made with natural ingredients" "Cures anxiety," "Treats chronic pain," "Prevents inflammation" Focus Positive, compliant messaging Red flag phrases and implied disease claims Role Guide creators on marketing tone Prevent legal exposure & FTC violationsAsk yourself this: while approved language encourages creators to market confidently, the prohibited claims list is what protects your brand from ftc scrutiny. Both should be distributed clearly and updated regularly with examples.
Health Products Claim Limits and Implied Disease Claims
Health-adjacent products like hemp and CBD often fall under tight scrutiny because the FDA and FTC strictly prohibit disease treatment claims unless the product is approved as a drug. Implied disease claims are tricky because creators may use casual language that inadvertently suggests medical benefit.
Examples of implied disease claims to avoid include:
- "Feel anxiety melt away"
- "Helps you get rid of your arthritis pain"
- "Supports your immune system to fight off colds"
These statements, even if subtle, hint that the product treats or mitigates a disease or condition, crossing FTC boundaries.
In contrast, compliant language emphasizes general wellness or lifestyle benefits without promising health outcomes:
- "Promotes relaxation and calm"
- "Supports your overall well-being"
- "Made from premium hemp for daily balance"
Brands like Joy Organics utilize this “plain language examples” approach in training sessions and in their affiliate portals, ensuring creators understand exactly which phrases raise red flags.
How to Construct Your Prohibited Claims List: Step-by-Step
- Start with a thorough FTC guideline review. Understand what types of claims are restricted — particularly those related to disease and health treatments.
- Identify your product category risks. Hemp/CBD brands face specific challenges around anxiety, pain, sleep, and immunity claims.
- Create a clear, concise prohibited claims list focusing on red flag phrases. For example, "cure," "treat," "prevent," "diagnose," and subtle variations like "eliminate" or "melt away."
- Use plain language examples. Break down prohibited claims into simple terms creators use daily. For instance, instead of "reduces inflammation," explain why this is a “red flag phrase” and offer an alternative: “helps you feel comfortable.”
- Pair your prohibited claims list with an approved claims list. This builds confidence and creative freedom while maintaining compliance boundaries.
- Integrate training and ongoing monitoring. Use platforms like Tomoson to create educational campaigns and implement audits on public posts, especially across Meta and Google channels.
- Regularly update your list. Regulations evolve, and so do FTC enforcement priorities. Schedule quarterly reviews and gather feedback from creators to refine clarity.
Example: Red Flag Phrases to Include in Your Prohibited Claims List
Red Flag Phrase Why It’s Prohibited Recommended Alternative Cures anxiety Claims to treat a mental health condition May promote relaxation and calm Treats chronic pain Implies a medical treatment claim Supports overall comfort and well-being Prevents inflammation Suggests disease prevention Helps you maintain daily balance Eliminates cancer cells Serious unapproved disease cure claim Not permitted; avoid health-related disease claims Makes you immune to colds Implies immune system enhancement beyond structure/function claims Supports a healthy lifestyleLeveraging Tech Tools: Meta, Google, and Tomoson
Top e-commerce brands and agencies rely on a combination of technology and manual review to catch prohibited claims before they go live or spread widely. Meta's Commerce Policies and Google’s Advertising policies also prohibit certain health claims, so brands should ensure creators comply or risk takedowns.
Integrating these platforms’ APIs with affiliate management tools such as Tomoson allows brands to automate the monitoring process, flagging potential non-compliant posts quickly.
For instance, if an influencer shares a Meta post implying a disease claim about your CBD product, automated scanning can alert https://bizzmarkblog.com/what-should-i-do-if-a-creator-refuses-pre-approval/ your operations team for immediate correction, maintaining regulatory compliance and safeguarding your brand’s reputation.
Conclusion: Making Your Prohibited Claims List a Living Resource
Writing a prohibited claims list that creators truly understand requires more than a legal checklist—it demands simple language, concrete examples, and ongoing support. By following the best practices used by brands like Joy Organics and leveraging tools like Tomoson along with rigorous monitoring on Meta and Google platforms, your brand can confidently manage influencer risks in regulated categories.
Remember, your brand’s responsibility does not end at onboarding. FTC training, continuous monitoring, and periodic content audits are critical to maintaining compliance and fostering transparent creator relationships.
Start building your clear and actionable prohibited claims list today to protect your brand and empower your creators to market your products the right way—always on the right side of regulatory guidelines.