Product Examination Procedure
Version 1.0 · Effective November 10, 2026
1. Why
Under the FTC Endorsement Guides, an expert endorser must have actually exercised their expertise in evaluating the product, and must have examined or tested it at least as extensively as someone with the same expertise would normally need to support the conclusions presented (16 CFR 255.3(b)). If an ad says or implies that the expert personally uses the product, the expert must genuinely be a user at the time (16 CFR 255.1(c)). The paper review covers the evidence; the examination confirms that the actual product on sale is the one that evidence relates to.
2. When
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After the expert has approved at least one claim in the Review Form, and before any asset is approved or goes live.
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Again at each licence renewal, using a sample from a current lot.
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Again whenever the brand changes the formula, dose, ingredient form, supplier of an active ingredient or label.
3. What the brand sends
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A sealed retail unit from a current production lot, in final packaging with the final label, shipped at the brand's cost to the address the expert gives on the platform.
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The certificate of analysis for that lot, showing measured amounts of each active ingredient.
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Any third-party testing certificate, if the brand claims one.
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A note of any difference between this lot and the product described in the review dossier (there should be none).
4. What the expert checks
| # | Check | Result |
|---|---|---|
| 1 | Supplement Facts or ingredient panel matches the dossier: same ingredients, forms and amounts per serving. | ☐ Matches ☐ Differs |
| 2 | Dose per serving reaches the dose used in the supporting studies (as recorded in the Review Form). | ☐ Yes ☐ No |
| 3 | Certificate of analysis for this lot is consistent with the label. | ☐ Yes ☐ No ☐ Not provided |
| 4 | Directions, warnings, allergen statements and the FDA disclaimer appear on the label where required. | ☐ Yes ☐ No |
| 5 | No claim on the packaging goes beyond the claims the expert approved or that Legal cleared. | ☐ Yes ☐ No |
| 6 | Physical inspection (seal, appearance, smell, consistency) raises no concern. | ☐ No concern ☐ Concern |
| 7 | Personal use (optional, expert's choice, only if safe and appropriate for the expert): | ☐ Not used ☐ Used for ___ days |
Personal use is never required. An ad may say or imply that the expert uses the product only if the expert ticked personal use, confirms it is true, and approves that wording; the expert must tell the brand if they stop using it, and that wording must then be removed.
5. Confirmation (platform step G1)
☐ I have received and examined the product sample from lot [number], expiry November 10, 2026, received on November 10, 2026. The product matches the product I reviewed, and my endorsement reflects that examination.
Fields stored: lot number, expiry, date received, results of checks 1 to 7, notes, timestamp, expert ID.
6. If something does not match
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Any “Differs”, “No” or “Concern” in checks 1 to 6 stops the process. No asset may go live.
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The brand must explain the difference. If the product differs from the reviewed product, a new claim pre-check and a new review are required.
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If an asset is already live and a later lot or reformulation differs, the brand must pause the asset and notify the expert; the expert may withdraw for cause under the Agreement.
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Any safety concern is reported to the brand, which is responsible for assessing it and for any FDA reporting.
7. Records
The confirmation, check results and certificate of analysis are kept with the licence records for as long as any asset using the expert's name is live and then for 6 years.