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ARTICLE · 22 SEPTEMBER 2026

NAD Addresses Disclosure Requirements For Incentivized Reviews

Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
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Kelley Drye & Warren LLP

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When Zuru ran a program encouraging consumers to post product reviews in exchange for reimbursement, Procter & Gamble challenged the practice before NAD, arguing that consumers weren't instructed to disclose the incentive. While Zuru maintained the program wasn't problematic since reimbursement didn't depend on positive sentiment, the company agreed to require clear disclosure of the financial incentive in future reviews.

United StatesConsumer Protection
Gonzalo E. Mon
Gonzalo E. Mon

Procter & Gamble recently filed an NAD challenge against Zuru, a New Zealand-based consumer products company, over a program Zuru ran to encouarge consumers to buy Zuru’s products, post reviews on retailer websites, and submit screenshots of those reviews to obtain reimbursement. Consumers were allegedly not instructed to disclose that the reviews were incentivized. 

Zuru responded that the program wasn’t problematic because reimbursement wasn’t contingent on positive sentiment, favorable ratings, or endorsement of any product attributes. Nevertheless, the company volunteered to modify its practices by instructing consumers to clearly and conspicuously disclose that Zuru had reimbursed the purchase price of the reviewed product. 

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