User reviews in marketing (short version)

Are you a seller of goods or services who allows users to leave feedback in the form of user reviews? Here’s how to follow the law.
  • As a trader, you may not write user reviews or let others write them on your behalf and present the reviews as if they came from a consumer.
  • Your system for obtaining user reviews must not steer the assessments in any particular direction, as with e.g. a template for writing user reviews that sets the scene for a positive review.
  • You may not delete negative reviews solely because they are negative. This will lead consumers to believe that your customers are more satisfied than they actually are.
  • Furthermore, you may not summarily suppress or reject reviews simply because you determine them to be irrelevant, or because you believe the messages ought to have been directed to customer service.
  • If you use aggregated ratings (e.g. star rating scales), you should clearly and explicitly state the number of consumers that have left reviews.

 The use of rewards or incitements

  • If you encourage people to leave reviews by distributing free products in exchange for the reviews, the reviews will likely be considered advertising and must be labelled as such.
  • Blurring the lines between real user reviews and advertising must be avoided. If paid reviews are published in the same place as ordinary user reviews, they must be presented in clear separation from one another.
  • Paid reviews may not be included in star ratings or other summaries of consumers’ assessments.
  • In some cases, rewards may be used without the reviews being considered advertising. The reward must be low, and it must be clearly and explicitly stated that the consumer has an equal chance of receiving a reward if the review is positive or negative
    • Example: All customers who purchased a good or service are notified that they can be included in a drawing for a gift card of a relatively low amount if they leave a review. At the same time, it is made clear that a positive or negative review will not affect their chances of winning

Take steps to prevent cheating

  • You must assess the need for systems that ensure user reviews on your site are genuine.
  • If you find it necessary to delete user reviews that are e.g. offensive, abusive or false, you must clearly and explicitly explain to the customers what types of reviews may or may not be published. The customer may then decide whether he or she will submit a new review if the first one was removed

Follow the law

Traders that employ user reviews to market themselves or their products must follow the requirements on marketing in the Marketing Control Act. The Consumer Authority has prepared guidelines, “User reviews in marketing”, which provide more information on how you can follow the law. The Consumer Authority has the authority to prohibit illegal marketing, and can impose infringement penalties in special cases.

 

20.09.2019

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