TTB Publishes Social Media Guidelines for Beer & Alcoholic Beverages

The TTB has updated their guidelines for using social media with Alcoholic beverages.  Here’s a snippet and the full report is here:

A social network service is 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 industry members have created pages on social network services for their company and/or a particular brand.  These are sometimes referred to as “fan pages” or “pages,” and users of the social network service can become “fans” of the company or brand, creating a link between their own page and the fan page.  The purpose of fan pages is to increase brand awareness and loyalty by allowing industry members to communicate with consumers in an interactive manner.  TTB considers fan pages for alcohol beverage products or companies and any content regarding alcohol beverage products posted to the pages by the industry member to fall under the category of “any other media” in TTB’s regulatory definition of advertisement, and therefore the fan pages are subject to the provisions of the FAA Act and TTB regulations.

Because TTB considers industry member fan pages for alcohol beverages to be advertisements, all mandatory statements required by the regulations (in §§ 4.62, 5.63, and 7.52) must be included on them.  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 regulations require that mandatory statements on alcohol beverage advertisements be:  (1) conspicuous and readily legible; (2) clearly a part of the advertisement; and (3) readily apparent to the persons viewing the advertisement.  Thus, mandatory statements may not be hidden or buried in an obscure location on the fan page. 
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