Comment submitted to the US Federal Trade Commission on Endorsement Guidelines update

This is a response to the FTC solicitation for public comments relating to the amendment of the FTC Endorsement Guides in the light of the activity of social media influencers/content creators. Our comments draw on several academic interdisciplinary research projects starting as early as June 2018, leading to various types of output, including the first edited volume to address the regulation of social media influencers from a European perspective. Generally speaking, influencer marketing is a phenomenon that has empowered millions of social media users, turning them into entrepreneurs with high digital literacy skills. At the same time, to ensure that this industry is sustainable in the long run and reaps its promised benefits, it is paramount that its activities do not endanger protected interests. This comment addresses the following questions from the Request for Comment: 3, 4, 6, 14-16, 20, 21 and 22.