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Influencer Disclosure Rules by Country

In the ten countries below, regulators treat gifted product as a connection creators may need to disclose, but the label and the threshold differ: the UK wants "Ad" upfront, Norway wants "reklame" or "annonse", and Germany's media authorities tie it to a €100 product value. Pick a country for its rule.

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Pick a country to see its regulator, the label wording it publishes, how it treats gifted product, and a sentence you can paste into a creator brief. The address updates so you can share the result.

Country

Ten countries where we could verify the gifted-product position from an official source.

Which country's rules apply depends on facts only you and a lawyer can settle. This shows the rules for the one you pick.

United States

Federal Trade Commission (FTC)

  • Required label

    No mandated wording. The disclosure must be clear and conspicuous. FTC staff advise disclosing above the "more" button on Instagram, and a disclosure only on a profile page fails.

  • Gifted product

    Free or discounted products are a material connection under 16 CFR 255.5, even if the advertiser does not require an endorsement in return. Disclosure is needed when a significant minority of the audience would not expect the connection. Advertisers should guide and monitor their endorsers.

  • Line for your brief

    When you post about the product we sent you, please label the post as advertising using a clear "#ad" style disclosure above the "more" cut-off, in the post itself. Free product can count as a connection with our brand, so please label the post even though you were not paid. Check the rules for United States: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-255/section-255.5

Sources: eCFR: 16 CFR 255.5 Disclosure of material connections; FTC: Disclosures 101 for social media influencers

Seed's gifting link tells creators what you are sending, so the gifted-product disclosure conversation starts with the order, not after the post. Install Seed on Shopify

Country-by-country table

One row per country: the regulator, the label it asks for, how it treats free product, and the official source. Wording is paraphrased from the linked pages; follow the link for the exact text.

Influencer disclosure rules for gifted product, by country (checked October 29, 2026)
CountryRegulatorRequired labelGifted-product ruleSource
United StatesFederal Trade Commission (FTC)No mandated wording. The disclosure must be clear and conspicuous. FTC staff advise disclosing above the "more" button on Instagram, and a disclosure only on a profile page fails.Free or discounted products are a material connection under 16 CFR 255.5, even if the advertiser does not require an endorsement in return. Disclosure is needed when a significant minority of the audience would not expect the connection. Advertisers should guide and monitor their endorsers.eCFR: 16 CFR 255.5 Disclosure of material connectionsFTC: Disclosures 101 for social media influencers
United KingdomAdvertising Standards Authority (ASA) and CAP; Competition and Markets Authority (CMA)A prominent "Ad", "Advert" or "Advertisement" label upfront. The ASA advises against "Gift/Gifted", "Sponsored" and "Thanks to [brand]". A brand tag alone, a label buried in hashtags, or one only in the bio falls short.The ASA treats gifted products and freebies as payment in kind, so a post about them generally needs an ad label. The CMA says hidden advertising is illegal.ASA: recognising ads on social media and influencer marketingGOV.UK (CMA): social media endorsements, guidance for content creators
FranceDGCCRF (Ministry of the Economy)The mention « Publicité » or « Collaboration commerciale » (or an equivalent mention suited to the format), clear, legible and identifiable on the image or video for the whole promotion (Law 2023-451, art. 5, as amended in 2024).The law does not use the word for gifts. DGCCRF's practical guidance lists « offert » as an example of an acceptable mention that shows the commercial nature immediately; that is an administrative reading, not statute text. Missing the mention is treated as a misleading commercial practice by omission.Légifrance: Law 2023-451 of 9 June 2023economie.gouv.fr: influenceurs, quels sont mes devoirs ?
GermanyLandesmedienanstalten (state media authorities); consumer-protection courts under the UWGAdvertising must be recognisable at first glance. A blanket note on the account is not enough, and each Instagram story slide in an advertising context needs its own marking (Medienanstalten labelling guide).The media authorities say product handed over free can still be advertising. Their guide requires labelling for free products only where the value (or the total from one brand) exceeds €100, but they also note that the Federal Court of Justice has held that the mere expectation of promotion can trigger the duty. Under Section 5a(4) UWG, consumer advocates say the influencer carries the burden of proving no consideration was given. Label when in doubt.Medienanstalten: guide to advertising labelling in online mediaVerbraucherzentrale: when is a social media post advertising?
NetherlandsAutoriteit Consument & Markt (ACM) supervises; Stichting Reclame Code (SRC) self-regulation, Reclamecode Social Media & Influencer MarketingThe consumer must be able to tell easily that it is advertising. A bare "@" mention or a discount code is not enough. SRC says Instagram's paid-partnership feature is usually clear enough, and that an #ad mark must be easy to access, for example at the front of a video.SRC treats receiving free products as a relevant relationship that must be disclosed, particularly where the influencer was asked to post about them. A 2024 ruling states that free products given to influencers who then post about them can affect the credibility of the advertising.Stichting Reclame Code: social media and influencer rules
SwedenKonsumentverket (Swedish Consumer Agency)It must be clear that it is advertising; Konsumentverket says to mark posts with the word "reklam". Wording, placement and colour of the marking all matter.Payment can be money or other economic benefit such as goods, so gifted product falls under the same rules. The company's responsibility cannot be contracted away to influencers, and influencers can share responsibility.Konsumentverket: influencers' ad posts, rules for companies
NorwayForbrukertilsynet (Norwegian Consumer Authority)"reklame" or "annonse", prominent and immediate, naming the advertiser. Words such as "gave", "gifted", "sponset" and "i samarbeid med" are not considered clear enough, and Instagram's "Betalt partnerskap" label alone does not satisfy the authority.If an influencer is invited to events or sent products because of their influence and the sender knows they will post, it will often be advertising that must be made clear to followers. Advertisers are expected to train influencers and check their posts.Forbrukertilsynet: guide to labelling advertising in social media
DenmarkForbrugerombudsmanden (Consumer Ombudsman)"reklame for [brand]" or "annonce for [brand]" as the first thing in each post, with every post marked individually. Platform labels alone are not recommended. Posts in Danish need Danish labels.Free or discounted products, gifts, treatments, trips and event invitations all count as a commercial interest. If a company keeps giving products that the creator praises, the posts must still be marked as advertising.Forbrugerombudsmanden: hidden advertising on social media
AustraliaAd Standards (AANA Code of Ethics, section 2.7)The relationship must be clear, obvious and upfront, for example #ad, Advert, Advertising, Branded Content, Paid Partnership or Paid Promotion. Labels such as #sp, Spon, gifted, Affiliate, Collab or "thanks to" may not be enough.Ad Standards panels have treated a gift as evidence that the advertiser expects a post. The Code applies where the advertiser has a reasonable degree of control over the content, and the Practice Note says that where a brand sends free product with no control over what is said, the post is unlikely to be advertising. The AANA code is under review.Ad Standards: influencer marketing, a guide to disclosing ad contentAANA: Code of Ethics practice note (February 2021)
CanadaCompetition Bureau (Competition Act); Ad Standards (Influencer Marketing Disclosure Guidelines, updated 2025)Disclose the nature of the connection clearly and prominently, close to the claim, for example #Gifted or #InvitedGuest. Ad Standards lists #Ambassador, #Partner and #Collab as ambiguous. The Bureau says tagging a brand or posting a discount code is unlikely to be enough.The Competition Bureau lists free products or services as an example of a material connection that should be disclosed. The 2025 Ad Standards guidelines give separate direction for gifted products versus event invitations.Competition Bureau: influencer marketing and the Competition ActAd Standards: influencer marketing resources

Not in the table: Italy and Spain. Both have influencer rules (Italy through AGCOM guidelines and the IAP Digital Chart, Spain through the General Audiovisual Communication Law for "users of special relevance"), but we could not confirm from an official source how they treat free product, so we left them out rather than guess.

What to put in your gifting brief

Four points show up across the regulators above. Each is attributed, so you can check it.

Put the label in the post, up front

The ASA expects a prominent label upfront, the FTC says to disclose above the "more" button, Denmark wants the label as the first thing in each post, and France requires the mention to stay visible for the whole promotion.

Do not rely on "gifted" or "thanks to"

The ASA, Australia's Ad Standards and Norway's Forbrukertilsynet all say those wordings can fall short, and Canada's Competition Bureau says a brand tag or discount code alone is unlikely to be enough.

Add words to the platform label

Norway and Denmark steer creators to add a plain advertising word on top of Instagram's partnership label, and the FTC warns that a small, low-contrast built-in label can fail.

Brief it and check it

The FTC, Sweden and Norway all put some responsibility on the advertiser. Write the wording into the brief, and look at posts when they go live. The influencer brief generator and the influencer contract generator can carry it.

Frequently asked questions

Do creators have to disclose gifted products?

In the ten countries below, the regulator treats free product as a connection a creator may need to disclose when posting about it. The FTC lists free products as a material connection, and the UK ASA treats gifts as payment in kind. Details differ by country, so check the table row for yours.

Is "gifted" an acceptable label?

It depends on the country. The UK ASA advises against "gifted", Australia's Ad Standards says it may not be enough, and Norway's regulator does not consider it clear enough. Canada's Ad Standards uses #Gifted as an example. When unsure, lead with the local word for advertising, then say the product was gifted.

Who is responsible for the label, the brand or the creator?

Both can be. The FTC says advertisers should guide and monitor endorsers and that the influencer may also be liable. Sweden's Konsumentverket says a company's responsibility cannot be contracted away, and Norway expects advertisers to train influencers and check posts. Put the label wording in your brief and check posts.

Does Instagram's paid partnership label count as disclosure?

Not reliably. The Dutch SRC says it is usually clear enough, but Norway's regulator wants "reklame" or "annonse" added, Denmark's ombudsman does not recommend platform labels alone, and the FTC says relying only on a small, low-contrast built-in label can fail. Add a plain-word label in the caption.

Is there a minimum product value before disclosure is needed?

Only Germany's media-authority guide sets one in the sources we read: €100 for a product or the total from one brand, though courts and consumer advocates take a stricter view. The FTC test is whether a significant minority of the audience would not expect the connection. We found no other country's value threshold, so label when unsure.

Which country's rules apply to my campaign?

That depends on facts such as where the audience is and where the brand and creator are based, and this guide cannot decide it for you. If creators or audiences span several countries, use the strictest label in the table, and ask a lawyer before a large campaign. This is not legal advice.

Methodology and sources

Last updated: October 29, 2026

For each country we read the regulator's own guidance (or the statute text it points to) on 29 October 2026 and recorded three things: the label wording published, the gifted-product position, and the page it came from. Where an authority did not say something, the table says nothing rather than filling the gap. Self-regulatory bodies (UK ASA, Dutch SRC, Ad Standards in Australia and Canada) set codes that are enforced differently from statute; the regulator column names which is which.

What we did not verify: Italy and Spain (omitted); how each country decides which law applies to a cross-border post; penalties; sector rules for categories such as supplements, cosmetics or alcohol; platform policies; and anything published after October 29, 2026. Germany's €100 figure comes from the media authorities' guide and is in tension with the courts' stricter view, which we report rather than resolve. The brief wording is our paraphrase of each regulator's published labels, not an official template.

This is not legal advice. Rules and thresholds change, and each rule below depends on facts we cannot see. Check the linked official source for your case and ask a qualified professional before you rely on it. Last checked October 29, 2026.

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