A snack brand ships a case to twelve creators with one line of direction: "tell people why you love it". Eleven videos come back with the words the brand's own packaging uses. The twelfth creator, who loves it most, says it is "all natural, low in sugar and good for your heart". Three claims in one sentence, each with a different legal status in the United States, none of them written by the brand, and the video is the best of the twelve. That is the problem an American food brand has with creator content, and it is not a problem of enthusiasm. It is that the vocabulary of eating and the vocabulary of food labeling overlap almost completely, and only one of them is regulated.
The general craft of food UGC, the kitchen, the pour, the reshoot rather than the rescue, is in the guide to UGC for food and beverage brands. This guide is about the American layer: the three categories of claim the Food and Drug Administration defines, the word "natural" that it has never formally defined, and how a brand keeps twelve creators inside a vocabulary it can defend.
Three categories of claim, three regimes
Health claims
The FDA's page on label claims sets out three categories defined by statute and regulation. A health claim describes a relationship between a food substance and reduced risk of a disease or health-related condition, and it is the most tightly controlled: the FDA authorizes which health claims may be used, through the Nutrition Labeling and Education Act and the procedures that followed it. "Good for your heart", said by a creator about a snack, is the shape of a health claim, a food and a reduced risk of a condition, and it is not the creator's to make.
Nutrient content claims
A nutrient content claim describes the level of a nutrient in the product using terms such as "free", "high" and "low", or compares it with another food using terms such as "more", "reduced" and "lite". The FDA's page states that these terms are regulated and may be used only if they have been authorized and used in accordance with the authorizing regulations, whereas an accurate quantitative statement, the page's example is "200 mg of sodium", may be used to describe the amount of a nutrient present as long as it does not otherwise characterize the level. The page's own counter-example is "only 200 mg of sodium": the word "only" characterizes the level as low, and the food then has to meet the criteria for "low" or say that it does not. That distinction is the single most useful thing a food brand can put in a creator brief: "5 grams of sugar per serving" is a number the creator can read off the label; "low in sugar" is a regulated term with a definition the creator has not checked.
Structure/function claims
The third category, structure/function claims, may describe the role of a nutrient or dietary ingredient intended to affect the normal structure or function of the body, the FDA's own examples being "calcium builds strong bones" and "fiber maintains bowel regularity", and it is the category functional food and drink marketing reaches for. The FDA's page states that these claims are not pre-approved but that the manufacturer must have substantiation that the claim is truthful and not misleading, that they may not explicitly or implicitly link the effect to a disease, and that conventional foods differ from supplements on two points: food claims focus on effects derived from nutritive value, and neither FDA notification nor the disclaimer is required for claims on conventional foods. The guide to UGC for supplement brands in the United States covers the supplement side, disclaimer included. For a food brand the working rule is: a function, never a disease, and substantiation in hand.
| What the creator says | FDA category | What it needs |
|---|---|---|
| "Good for your heart", "helps prevent diabetes" | Health claim | FDA authorization; not for a creator to improvise |
| "Low in sugar", "high in protein", "lite", "reduced sodium" | Nutrient content claim | An authorized term used as its regulation defines it |
| "12 grams of protein per serving" | Quantitative statement | Accuracy against the label, nothing more |
| "Supports digestion", "helps you stay full" | Structure/function claim | A function, not a disease, and substantiation |
| "All natural" | No formal FDA definition; longstanding policy | The brand's own decision about what it can defend |
The three categories are label categories. In a creator video the FTC applies its own test to the same words, and its guidance says it follows the same steps whatever the FDA would call the claim: any health-related claim needs competent and reliable scientific evidence.
The word "natural"
The FDA states plainly that it has not established a formal definition for the term "natural", and describes its longstanding policy instead: the agency has considered "natural" to mean that nothing artificial or synthetic, including all color additives regardless of source, has been included in or added to a food that would not normally be expected to be in that food. The same page is explicit about what the policy does not cover: it was not intended to address production methods such as pesticide use, it did not explicitly address processing methods such as pasteurization or irradiation, and the FDA did not consider whether the term should describe any nutritional or other health benefit.
For a brand that is three decisions in one. A creator who says "all natural" about a product with an added color is contradicting the policy on its own terms. A creator who says "natural" to mean organic, unprocessed or healthy is saying something the policy never meant, which the brand will have to defend on its own. And a brand whose product fits the policy still has to decide whether a viewer hears the word the way the FDA reads it, because the Federal Trade Commission's standard for any advertising claim is what a reasonable consumer takes from it, and the FTC's health products guidance is clear that claims about the health benefits of foods require substantiation in the form of competent and reliable scientific evidence.
The testimonial that becomes a claim
Food content is testimonial by nature: a person eating, enjoying, describing. Most of that is not a claim in the regulated sense, and a brand should let creators be creators. The line is crossed when the description becomes an effect: "I have more energy", "I lost weight", "my kids stopped getting sick". The FTC's guidance treats a consumer testimonial as a claim the advertiser is making, holds the advertiser liable for misleading endorsements in social media as elsewhere, and its testimonial rule applies as the guide to UGC for fitness brands in the United States sets it out: a result more dramatic than typical is likely deceptive, and "Results not typical" cures nothing. A snack that made one creator feel fuller through the afternoon is a fine video; a brand that runs twelve creators saying it changed their lives has made twelve claims.
The disclosure is the same as in every category: the FTC's influencer guidance asks for a clear statement of the material connection with the endorsement, and a case of product sent free is that connection, whether or not a post was asked for: the guidance says to disclose it even when the brand never asked for a mention. In food, where seeding is the ordinary way to start, the disclosure should be in the brief before the box ships.
Alcohol, and what this guide does not say
Beverage brands that sell alcohol are not covered by this guide. Alcohol has its own federal regulator and its own state rules, and none of them are stated here; a brand in that category should treat the whole of this guide as the general layer and take the category's own rules from its regulator and its counsel before briefing a creator.
The brief a food brand should send
- Copy the label's nutrient numbers into the brief and tell creators they may read any number as it is written, may not put "only" in front of it, and may not turn a number into "low", "high", "lite" or "reduced".
- List the health words that are off limits, heart, blood sugar, cholesterol, any disease, and give the reason in one line: those are claims the FDA authorizes, not sentences a creator writes. Function words, digestion, immune health, fullness, are allowed only in the exact structure/function form the brand has substantiated, and never linked to a disease.
- Decide the brand's position on "natural" before the shoot, with the FDA's policy in front of the person deciding, and put the decision in the brief as a yes or a no.
- Ask creators to describe eating, taste, texture and moments, and to keep effects on the body for the brand's own substantiated wording.
- Write the disclosure into the brief before the case ships, and check it on every video that comes back.
Sources
- FDA, Label Claims for Conventional Foods and Dietary Supplements
- FDA, Use of the Term Natural on Food Labeling
- Federal Trade Commission, Health Products Compliance Guidance
- Federal Trade Commission, Disclosures 101 for Social Media Influencers
Checked on 20 September 2026. This guide is not legal advice. Where this guide and the official source disagree, the official source prevails.
