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An internal result is not automatically a publishable claim. A team may have measured a change accurately while the proposed headline describes a different metric, implies causation or presents one merchant’s result as a typical outcome. The review must connect the exact public statement to the evidence that supports it.

This matters for a purchase-reward campaign because the product’s appeal can tempt marketers to promise increased sales before the supporting work exists. A useful substantiation record makes the claim, its limits and its approved wording reviewable before the statement appears on a page, in a presentation or in a creator’s script.

Identify the express and implied performance claim

Write down the statement exactly as customers will encounter it, including nearby charts, images and qualifications. “Sales increased during the campaign” and “our reward program increased sales” can convey different causal claims even if both refer to the same reporting period.

The FTC’s advertising substantiation policy calls for a reasonable basis for objective claims before dissemination. The type and strength of evidence need to match what the advertising expressly or implicitly represents. FTC advertising substantiation policy

Consider a hypothetical internal report showing 40 purchases from 1,000 measured visits in one period and 50 from 1,000 in another. The measured conversion rate changed from 4% to 5%, a one-percentage-point increase and a 25% relative increase. Those numbers do not, by themselves, establish that a rebate caused the change or that sales revenue rose by 25%.

The proposed headline “Rebates increase sales by 25%” therefore introduces several questions. Does “sales” mean orders or revenue? Is the statement causal? Does it imply that other merchants can expect the same outcome? Was the comparison designed to support those inferences? The reviewer should identify those implications before debating a footnote.

A claim inventory can separate them:

Proposed message Claim that needs support
“Conversion was 5% in this measured period” Accuracy and scope of the reported rate
“Conversion increased by 25%” Correct relative comparison and comparable populations
“The rebate caused the increase” Evidence supporting the causal attribution
“Merchants typically see this increase” Evidence supporting the typical-result implication
“Guaranteed sales growth” The much stronger promise actually conveyed

The numbers are fictional. They illustrate claim review and cannot be used as RebateCardX performance evidence.

Match the claim to supporting evidence

The evidence file should identify the source, measurement definition, population, period, comparison and relevant limitations. It should also say what the evidence does not establish. This article does not redesign the measurement study; it reviews whether the existing study supports the proposed public use.

For the hypothetical report, note whether traffic sources, product availability, pricing or other promotions differed between the two periods. If the analysis did not isolate the rebate’s effect, do not convert a temporal association into a causal product promise through wording.

A substantiation record can be filled as follows:

Field Hypothetical entry
Claim under review Rebate campaign increased sales by 25%
Evidence available Two measured periods with conversion rates of 4% and 5%
Metric actually measured Purchases divided by measured visits
Unsupported implication Revenue increase, causal attribution and typical merchant result
Permitted use decision Do not approve the broad headline from this evidence
Possible narrower description A accurately scoped internal period comparison, subject to review
Required additional evidence Whatever is needed to support the proposed stronger claim

A narrower description still needs review in its actual context. A chart headline can imply causation even if a sentence underneath uses cautious wording. The net impression of the presentation matters, including what a reasonable reader is likely to take away.

A difficult case is a customer testimonial with an impressive result. The customer’s experience may be real, but the advertisement can still imply that the result is representative. Review the actual endorsement context and the support for any typical-outcome implication. A generic “results may vary” line is not a substitute for evaluating the claim being made. FTC endorsement guidance

Keep permissions and factual support separate. Having permission to use a customer’s quote does not prove the quote’s performance claim is substantiated. Conversely, having an internal report does not automatically provide permission to identify the customer publicly.

Approve wording and retain its review history

Approve a specific version for a specific use. The record should include the final wording, visual context, source evidence, limitations, reviewer and review date. A blanket approval of “the case study” can become ambiguous when a sales team later extracts a stronger sentence for an advertisement.

State the approved distribution scope. A detailed article with its comparison context may support a different presentation from a short social graphic. If a shortened format removes the information needed to understand the claim, review the shortened version separately.

Define refresh triggers. A change in the product capability, measurement correction, new contradictory evidence or a materially different audience can require renewed review. The trigger should relate to the claim’s support rather than an arbitrary calendar reminder alone.

For the fictional conversion comparison, the final record might decline the causal headline and approve only a carefully scoped description of the measured periods. If the team later obtains stronger evidence, it can submit a new claim version. The old rejection remains useful history explaining why the earlier statement was not publishable.

Check active copies after approval. A corrected website sentence does not update a sales deck, creator script or downloadable graphic automatically. Maintain an inventory of the claim’s known uses and assign someone to replace or withdraw outdated versions when the support changes.

The practical result is a substantiation file that connects each public promise to evidence of the same scope and strength. It allows RebateCardX-related marketing to describe what is actually established while leaving unsupported performance promises out of the customer-facing message.

Discuss accurate capability statements for your proposed Rebate Card X program before promoting results.

Discuss program fit

Source references

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General information only

This guide is general information, not financial, legal, tax or regulatory advice. Eligibility, card availability, permitted use and responsibilities depend on the applicable offer and card terms.