If you put your product #1 on the “best of” list, it’s not just a search quality issue – it could be violating FTC rules that go into effect in October 2024.
Driving news. As Lily Ray noted on LinkedIn, the FTC’s Consumer Review Act (16 CFR Part 465) prohibits several deceptive practices tied to reviews and testimonials, including:
- Present company-controlled content as independent reviews.
- Publishing reviews of products or services is never really used.
- It features reviews from people who didn’t write them.
Penalties can be up to $53,088 per violation, and each page may be calculated separately. Ray also shared the reference table he produced with Claude’s help:
Why now. “The best X” and “Top 10 Y” listicles have grown as a GEO tactic over the past few years. These pages tend to perform well in search and have a huge impact on AI-generated results.
The backstory. Before the law was enacted, Ray said at least one company faced legal action for publishing hundreds of “best of” pages that said:
- It ranks its services #1.
- Includes innovative competitor reviews.
- Used fake reviews on third party platforms.
The Better Business Bureau later criticized the company for unsubstantiated claims.
What’s going on. Most of today’s listicles follow a similar pattern:
- The brand publishes a list of “best tools”.
- Including competitors that haven’t checked yet.
- Uses direct or invented scoring systems.
- The standard itself is #1.
These lists may imply independence or self-assessment where none exist.
The nuance. You can publish comparative content that includes your product. However, based on FTC guidance, the risk increases when:
- He suggests disrespect, but improve your brand.
- He presents reviews that are not based on real information.
- He fails to clearly disclose material relations.
What Google says. Google is aware of the low quality listicle trend. In a statement to The Verge, a Google spokesperson said the company uses anti-fraud in Search and Gemini, and reiterated its guidance: create content for people and make sure it’s understandable for search engines.
Why do we care. What worked as a visibility tactic may be vulnerable to two things – regulators and a radical change in Google’s search algorithm. That means that this popular GEO strategy could quickly decline as its effectiveness declines.
A Caveat. I am not a lawyer. Consult your legal counsel if you are concerned about using this strategy.
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