The best line in the video is usually the one you will have to cut.
It is the unscripted one, the sentence that arrived because the creator forgot the brief for four seconds and said what they actually thought. It is the reason you bought UGC instead of an advert. And it is the line that says the thing you cannot prove.
Everything the creator says is your claim
This is the part brands underestimate, because the format feels like someone's opinion and legally it is your advertising.
The brand carries it, not the creator
When a piece of content is advertising, the advertiser is responsible for what it says. That does not change because the words were improvised, because you did not approve them, or because the creator believed them.
You commissioned a video. What is in the video is your message. If a sentence in it cannot be supported, the fact that somebody else said it first is not a defence, and the fact that it was sincere is not either.
Personal experience is not automatically safe
There is a widespread belief that anything phrased as experience is fine. It is close to true and the gap is where the problems live.
Saying that a moisturiser felt nice is experience. Saying that it cleared their skin in a week is an efficacy claim wearing the clothes of experience, and it will be read as a claim about what the product does. The tell is whether the sentence would still be checkable if a stranger repeated it: I liked it is not checkable and does not need to be, it worked in a week is.
The same applies to durability, savings, comparisons with other products, and anything about health.
| What the creator says | Why it is a problem | What to ask for instead |
|---|---|---|
| It cleared my skin in a week | Efficacy claim, needs evidence | Show the routine, say what you noticed |
| It lasts twice as long | Comparative claim, needs a basis | Name your own usage, not a multiple |
| It is completely plastic free | Absolute environmental claim | Say what part is, and what it replaced |
| It saved me a fortune | Savings claim, needs a comparison | Say what you used to buy instead |
| I have used it every day since | Experience, and it is genuinely useful | Nothing, this is the good version |
The last row is the point of the table. The safest line is also the most persuasive one, which is unusual and worth exploiting.
Green claims are where this bites hardest
Environmental language is the single most common source of trouble, because it is the language creators reach for naturally and because it is under real scrutiny in the UK.
The Advertising Standards Authority publishes rulings on environmental claims, and the Competition and Markets Authority has published guidance on green claims for businesses. Both are current, both are updated, and neither should be summarised in an article that will age, including this one. Read them before you brief anything with the word sustainable in it.
The practical version for a brand commissioning UGC: words like eco, natural, sustainable, carbon neutral and plastic free are not descriptive words in an advert. They are claims with a specific meaning, and an absolute one is much harder to support than a specific one. Recyclable packaging is a claim you can evidence. Plastic free is a claim about the entire product, and creators say it constantly because it sounds like a compliment.
Give them a claim they can make
The fix is not to ban adjectives, because a video that says nothing about the product does not sell anything.
Give the creator one substantiated claim, in plain language, that they are allowed to say however they like. The bottle is made from recycled plastic. It is refillable. It is made in Yorkshire. Whatever your evidence actually supports, hand it over as a sentence they can put in their own words, and tell them explicitly that everything else should be about their own experience.
That single instruction changes the footage. It gives them something concrete to hold, which improves the delivery, and it moves the claim from something improvised into something you have already checked.
What to do with the footage you have
If you are reading this with videos already delivered, watch them with a pen and write down every sentence that makes a statement about the product rather than about the person.
Then sort that list into things you can evidence and things you cannot. Anything in the second column comes out, and cutting it is usually painless: it is one sentence in a spoken paragraph, and a competent edit removes it without anybody noticing.
What you cannot do is run it and hope. Content stays online, rulings are public, and a complaint about a claim in a video reaches the brand rather than the creator.
Keep reading
- The Zero in Your Gifting Budget
- Casting a British Voice for UGC
- UGC Advertising Disclosure Rules in the UK
- What Nobody Tells You Before Your First Tax Return
- The complete UGC guide for the UK
Frequently asked questions
Can we just add a disclaimer saying these are personal opinions?
Not usefully. A disclaimer does not turn a claim into an opinion, and if the sentence would be read as a statement about the product, it is treated as one regardless of what the caption says.
What if the creator says it in a story rather than the paid video?
If it is part of the commissioned work, treat it the same way. Ask to see stories before they go up on a paid campaign, or write into the brief that the substantiated claim is the only product statement anywhere.
Does this apply to comments the creator leaves?
Replies from the creator on a commissioned post are part of the same advertising in practice, and a promise made in a comment is the sort of thing that surfaces later. Agree in advance what they say if asked whether it cured something.
Where do we check the current rules?
The ASA and the CAP Code for advertising standards, and the CMA guidance for green claims. Both publish real examples, which teach faster than any summary.
Sources
Checked on 27 August 2026. Thresholds and rates change: where this guide and the official source disagree, the official source is right.