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Working With Influencers: FDA Guidelines

Working with social media influencers to promote your health and wellness brand online can be a great way to round out your marketing strategy. There are a few things you should consider before preparing to work with an influencer, including your brand’s philosophies, marketing goals, and intended audience. We have simplified your path to partnering with influencers by compiling a straightforward guide that incorporates these factors and can help you decide how best to get started.

Who are Influencers?

Influencers are people with followings on social media beyond their personal social circle who use their platform to impact an audience’s decisions, usually to the end of encouraging people to buy a product or take on a certain lifestyle.

Influencers can range from celebrities to the pillars of very niche communities, a wide spectrum that makes them a great choice for promoting brands of all sizes. Influencers provide a unique ability to cater to a specific audience through their own voice and Personal Brand (their values, the lifestyle they promote, and the kinds of products they believe in.) This is invaluable in health and wellness marketing, such as for supplement or skincare brands, where influencers can use their reach to promote positive messages about your products to an audience with relevant interests and health goals.

Are Influencers Right to Promote your Brand?

Working with Influencers can be a powerful tool for a variety of brands, but it is important to consider whether they suit your brand’s specific goals. Collaboration with influencers is most effective when a brand is trying to promote a specific product or message. Health and wellness brands should outline their goals before determining whether an Influencer is a good choice for marketing going forward. Ask yourself these questions to gauge whether your brand might benefit from promotion online via influencers:

  1. Am I promoting a specific product or range of products that can be easily incorporated into social media content?

  2. Do I have a clear vision for the message or philosophy of my brand that an external influencer could adopt and share in their own voice? These can involve product claims describing your formula's performance in clinical research!

  3. What is my target audience and are they best reached online?

Additionally, collaborating with an influencer may be most effective if you are launching a new product, or want to revive the media attention for an older one. It is vital to understand who the audience for your new product is, as without an idea of what their interests might be it can be difficult to pick an influencer that will be suitable for your brand’s needs.

Implementing Influencers

Content Creation

An influencer can create a variety of content that accomplishes your brand goals online. With health brands in particular there is a lot of creative leeway, as you are essentially working your products into a lifestyle that your customers want to attain.

For example, if your goal is to promote a new skincare product, you may work with an influencer on creating content that integrates your product claims into their daily skincare routine. Some common content options include:

  • A picture of the influencer using your product, with a caption incorporating some of your product claims

  • A video (such as an Instagram Reel or a TikTok video) where the Influencer showcases your product in action. This can take the form of a skincare routine tutorial or showcasing the item as a travel essential in their go-to skincare bag.

Protecting Your Brand: A Recommendation from the FDA

Brands should avoid equating influencers to spokespersons of their products because while they are essentially ambassadors for your brand during the duration of their work with you, influencers are effective online because they maintain their own autonomous Personal Brands. Further, Influencers are required by the FTC to disclose any financial partnership with a brand or product.

This means that it is vital to protect your brand’s interests by setting out clear missions for your collaboration and vetting any influencers you intend to work with, as it will be evident to audiences that you are engaging in paid promotional work.

From the FDA: "Thoroughly vet any potential influencers, create guidelines, and draft an agreement that manages your and the influencer's expectations, and create a mitigation plan, so that if anything unexpected happens, you have a plan for how to respond."

How to Vet an Influencer for your Wellness Brand

In order to mitigate risk, you'll want to thoroughly vet an influencer before reaching out for a partnership. Visit their social channels and review their content. If anything feels misaligned with your company, your brand, or your mission, move on to someone else.

Create a list of "red flags" that will help guide this vetting. The FDA lists these "red flags" as:

  • Hateful conduct

  • Violence/extremism

  • Misinformation (this is especially important when considering product claims)

  • Illegal or certain regulated goods or services

  • Suicide or self-harm

  • Abuse/Harassment

  • Sensitive media

The FDA recommends that vetting continues even after the partnership has been solidified.

"Vetting an influencer doesn't stop after they've been selected. Have a plan in place to assess the infuencer continually (either daily or weekly) througout the entire lifecycle of an influencer program."

How to Write Influencer Guidelines

After establishing a relationship with influencers, you'll want to ensure they follow your "dos" and "don'ts". Guidelines can be helpful for all parties involved. They'll give guidance to your influencer when creating content, without restricting creative freedom.

The FDA gives some considerations for guidelines, which include:

  • Your brand's history and mission

  • The goals of the influencer program

  • The motivation for working with this specific person (for example, highlight the content that you like so they can focus on creating content like that for your brand)

  • Messages you'd like the influencer to share

  • Potential "dos"

    • Ask the influencer to tag your brand

    • Mention your brand by name

    • Be considerate of other people when creating content

  • Potential "don'ts"

    • Bashing other brands

    • Using logos, songs, and artwork without permission

    • Having drugs or alcohol visible

    • Showing people without their consent

    • Explicit language

    • Shaming others, other brands, or other products

    • Using language that normalizes behaviors that could have unintended consequences

Mitigating Risk with Influencers

Even after proactive steps such as vetting, creating guidelines, and establishing an agreement, your brand should have a shared mitigation plan with an open and honest conversation with the influencer.

The FDA suggests your risk mitigation steps could include the following:

  • Discussing brand guidelines with the influencer at the beginning of the agreement

  • Removing the influencer's post (if reposted to your own channels)

  • Pausing paid media support from the influencer's post

  • Determining if any comments or actions will need to be addressed by your brand

  • Asking the influencer to delay posting to create space between your content and the problematic content

  • Getting confirmation from the influencer that their content will be brand-safe

  • Evaluating the relationship (continue, terminate, or pause)

  • Asking the influencer to remove the original content from their channel

There will always be risks associated with inviting others to represent or speak on behalf of your brand and your products. However, following these guidelines from the FDA can help you and your brand feel comfortable working with influencers. You'll benefit from the perks of reaching an extended audience through your influencer network.

Overview of Working with Influencers

Our simplified guide is adapted from information provided by the Center for Tobacco Products, and if you’d like an in-depth preparation for working with influencers you can read their “Influencers 101” guidance.

Before working with influencers, you should first identify your brand's goals, your target audience, and the takeaway message or product claims you're aiming to promote through your product.

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