Should Affiliates Use the Facebook Branded Content Tool?
As part of our continuing efforts to help educate the industry on disclosure requirements, the Compliance Council has been researching the issue of whether and to what extent affiliates need to use the Facebook Branded Content Tool (also known as the Handshake Tool). Toward that end, we have not only surveyed affiliates about their use but have spoken directly with Facebook about their requirements. What follows is a summation of those along with outstanding issues we have with the policy.
Facebook Says Affiliates Must Use the Branded Content Tool
Members of the PMA Compliance Council first spoke with employees at Facebook back in April of 2018. Since that time, we have received more clarification from them via email.
First, they point affiliates to the following policies that regulate both Facebook and Instagram:
Facebook defines “branded content” as “a creator or publisher’s content that features or is influenced by a business partner for an exchange of value.” In our conversation with them, they stated that the policy is meant to cover broad range promotional content from influencer marketing through to and including affiliate marketing.
Second, Facebook made it clear to us both verbally and in the email exchanges that branded content includes both:
- An affiliate who posts a direct affiliate link on Facebook, and
- An affiliate who posts a link to a blog post on Facebook where that blog post contains affiliate links.
Furthermore, the use of FTC compliant disclosure language (such as #ad) does not obviate the need to use the tool.
Survey of Affiliates
The Compliance Council conducted an informal, anonymous survey of affiliates who post links on Facebook. The links would include direct affiliate links or to blog posts that include affiliate links.
We first asked the affiliates whether they use proper FTC disclosure language in their Facebook posts and 72% responded either “Always” or “Sometimes.” Only 10% responded that they do not know what the rules are.
We next asked the affiliates whether they use the Facebook Branded Content tool when they post those links. Only 33% responded “Always” or “Sometimes.” In fact, almost 25% claimed to have no knowledge of the Facebook Branded Content Tool.
Arguments Against Using the Branded Content Tool
Because only 17% of the affiliates knew about FTC disclosure and chose not to use it, but 42% of affiliates knew about the Branded Content Tool and chose not to use it, we started talking to PMA members about why that is the case. Overwhelmingly the top reasons were:
- Tagging the merchant in the post would send customers directly to the merchant, thereby eliminating the possibility for affiliates to earn a commission.
- The social media team that approves the Branded Content submissions is often not the same as the affiliate team that manages the affiliate program and there is no easy way to police the use of the tags.
It’s too difficult to tag multiple merchants for a blog post that contains multiple merchant recommendations in the same post.
Are those arguments enough for affiliates to rationalize that they do not need to use the Branded Content Tool? As long as Facebook’s policy remains as it is, affiliates ARE obligated to use the Branded Content Tool. To do otherwise would subject the affiliate to having its Facebook account banned. However, it is our hope that further communication between our industry and Facebook can occur so that a mutually satisfactory result can be reached where affiliates are transparent about their relationships but not overburdened to the point of refusing to become compliant.
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