Idly flipping through Facebook one day, I saw a happy post:
“Doctors and scientists agree, red wine is good for health!”
So good, so far — if I were Roman, I’d have been at the temple of Bacchus.
But then, the dreaded violation of TTB Circular 2013 13-01 happened….
Immediately following that relink were two hashtags:
(My friend works at that winery. I’m not going to publicly harm a friend!)
To boot, the hastag was on that very same winery’s own FB account.
Blah! Let’s break down how that violated the TTB’s social media policy.
- 27 CFR 4.64(i)(1)(i) flatly prohibits any statement related to health without many many disclaimers attached (not withstanding statements about brix or caloric content).
- 27 CFR 4.64(i)(1)(ii) itself prohibits statements that imply a relationship about wine and a health condition.
- 27 CFR 4.64(i)(1)(iii) also prohibits a winery from directing or referring consumers to a third party regarding the effects of wine consumption on health.
The upshot is that I know that winery’s lawyer and was able to shoot a quick email over and that post was taken down within 15 minutes.
Your takeaway? Think about what you are reposting and retweeting. It’s nice to make something more personalized to your own brand, but not at the expense of violating the law! Better to avoid reposting than to inadvertently cross the line.
If you ever have any questions or concerns about your social media campaign, email or call me, anytime!