Manufacturers and advertisers are required by the Federal Trade Commission (FTC) to substantiate all claims, expressed or implied, that an advertisement conveys to reasonable consumers, with reasonable evidence before making the claim on the ad or package.

Claims Substantiation

Certain types of claims will require substantiation, in order to go to market. Common examples claims include:

  • Non-Comparative
    • Cleans soap scum
    • Streak free
    • Cuts grease
  • Category Claims
    • Cleans ceramic tile
    • Cleans glass
    • Will not harm marble
  • Parity Claims
    • Works as well as the other product
  • Superiority Claims
    • Product A is better than Product B
    • 4 out 5 dentists recommend…
    • Two times better than the leading brand

Other types of claims will not require substantiation. Examples include:

  • Puffery
    • World’s greatest cleaner
    • Surface shines like diamonds
    • Makes your laundry whiter than white

Frequently Asked Claims Substantiation Questions

Why Do I Need Claims Substantiation?

Companies making claims that catch the eye of their competitors and/or the FTC may have to defend the claims to the FTC, or via a voluntary process at the National Advertising Division of the Better Business Bureau (NAD).

If you cannot substantiate your claims, you may have to change your label, pull your advertising, or pay a fine.

How Do I Substantiate Claims?

The FTC and NAD will be looking for extrinsic evidence. Extrinsic evidence consists of tests, studies, or scientific research. Ideally, industry standard testing is performed using the actual product, and the results are used to support the claim. Anecdotal evidence or testimonials are not considered sufficient.

What Are The Industry Standard Tests For Cleaning Products?

The Household & Commercial Products Association (HCPA) and ASTM develop and publish widely-used and accepted industry standards for commercial and consumer cleaning products, including all-purpose cleaners, bathroom cleaners, glass cleaners, dishwasher detergents, laundry detergents, and degreasers.

Dell Tech is an active member of the HCPA and co-chairs the Scientific Affairs Committee that develops and publishes these industry standard testing methods.

Click here to view Dell Tech’s presentation of the testing cleaning products.

Click here to view Dell Tech’s presentation of the testing of laundry detergents.

If I am not making claims, do I need substantiation?

Yes, if you would like to know:

  • How well your product works
  • How your product compares to other products on the market


  • If you are a Toll Manufacturer making private label products and you need to demonstrate or require National Brand Equivalency


Dell Tech has solutions to substantiate claims for:

  • ASTM D2047 Static Coefficient of Friction of Polish Coated Floor Surfaces as Measured By The James Machine
  • ASTM D4488 Testing Cleaning Performance of Products Intended for Use on Resilient Flooring & Washable Walls
  • ASTM D4265 Evaluating Stain Removal Performance in Home Laundering
  • ASTM D5343 Evaluating Performance of Ceramic Tile Cleaners
  • ASTM D2047 Static Coefficient of Friction of Polish Coated Floor Surfaces as Measured By The James Machine
  • ASTM D3052 Standard Practice for Rating Water-Emulsion Floor Polishes
  • ASTM D3207 Standard Test Method for Detergent Resistance of Floor Polish Films
  • ASTM D3556 Deposition on Glassware During Mechanical Dishwashing
  • ASTM D3751 Standard Practice for Evaluation of Furniture Polish
  • ASTM D4009 Standard Guide for Foam Stability of Hand Dishwashing Detergents
  • HCPA DCC-05A Deposition on Glassware During Mechanical Dishwashing
  • HCPA DCC-09 Glass Cleaners
  • HCPA DCC-11 Home Laundering Pre-Wash Spotter Stain Removal
  • HCPA DCC-15 Measuring Degree of Surface Abrasion by Abrasive Cleaners
  • HCPA DCC-17 Greasy Soil Test Method
  • IKW Method for ascertaining the cleaning performance of dishwasher detergents
Dana Mladin

Dana Mladin

Senior Laboratory Technician, Regulatory Affairs Specialist

Call: 519.858.5021 ext 2070