If a well-known dog blogger reviews dog food they bought, no disclosure necessary. If they review free dog food acquired through a coupon spit out by the supermarket's computer, no disclosure is necessary. But if the dog food company sends the blogger a free sample based on their review, both the company and the blogger are on the hook if any subsequent review doesn't include that info.
And if they eat that dog food -- because, let's face it, the average blogger makes about 12 cents an hour and that Alpo Chop House Filet Mignon looks mighty tasty -- they must disclose that as well. (Unless they're actually a dog, in which case they fall under the disclosure guidelines created by the ASPCA.)
PC World's Ian Paul notes the same things can apply to anyone commenting on blogs, in forums, and in chat rooms. They apply to employees of a company who become a "fan" of their employer on Facebook or say something nasty about a competitor's product on Yelp.
My prediction: In six months the Net will melt down after being overwhelmed by the volume of disclosures that are required. (And, I would like to add, I did not receive any compensation for that endorsement of Alpo Chop House Originals, nor did my dog, Apache.)
According to IDG News, the FTC says the guidelines mainly target advertisers; bloggers themselves are unlikely to get fined, unless they continue to post bogus paid reviews after the FTC has scolded them for it.
Still, better safe than sorry. So here is my full disclosure:
* At various press functions throughout the course of my career, I have consumed 1,237 boiled shrimp (with 157 ounces of cocktail sauce), 112 pounds of smoked salmon, 4,879 crackers, and 32,718 cheese cubes. No money was exchanged for any of these. I would gladly give them all back if I could.
* I have two bankers boxes in my office filled with orphaned AC and DC adapters for gadgets I do not remember ever having in my possession (and because 99 percent of manufacturers do not stamp their logos on them, there's no way to know where they came from). I have another four boxes stuffed with random USB, Ethernet, RJ11, and serial cables. Send me a big pre-paid shipping container -- or possibly a semi-tractor trailer with a driver -- and they're yours.
* I also have a shoe box full of review-unit cell phones I used for a week and forgot to return; they are now too old to do anyone any good, but I'm too embarrassed to send them back and feel too guilty to sell them, give them away, and/or put them in landfill. I'm thinking seriously of just blowing them up. Anybody got any C4 they can spare?