Does your brand have a Facebook or Twitter page? Do you have a YouTube channel? Have you created a brand app? If you don’t have any of the above, you are likely in the minority. If you do, take note. The TTB recently released a social media industry advisory. The TTB defines a social media network as a “service, platform, or site where users communicate with one another and share media, such as pictures, videos, music, and blogs, with other users.” Many brands have created Facebook “fan” pages, the purpose of which is to “increase brand awareness and loyalty”. The TTB considers fan pages for alcohol beverage products or companies to be “any other media”, under TTB’s definition of advertisement.
Therefore, all mandatory statements required by TTB must be included on the social media pages. The good news: “TTB views the entire fan page (i.e., the ‘home’ page and all sub or tabbed pages directly associated with the ‘home’ page) as one advertisement, so mandatory statements need only appear once on the fan page, either on the “home” page or on any sub or tabbed pages directly associated with the ‘home’ page.”
The mandatory requirements that must appear on all alcohol advertising include identifying the (i) responsible advertiser; (ii) class and type designation; and (iii) alcohol content.
The mandatory must be: (i) conspicuous and readily legible; (ii) clearly a part of the advertisement; and (iii) readily apparent if viewing the advertisement. TTB recommends “placing mandatory statements in a location where a viewer would most logically expect to find information about the brand or the company.” Ideal locations are the Profile or About section.