Even if your answer is “no,” the United States Federal Trade Commission, whose stated mission is “preventing unfair methods of competition, and unfair or deceptive acts or practices in or affecting commerce,” thinks you need to know that information to gauge what — exactly — you are reading.
Although much has been written about how the agency’s recent efforts may affect influencers and celebrities who are paid to promote specific products or brands in subtle ways, the F.T.C. has made it clear that it has all areas of the fashion industry in its sights.
In other words, some day soon the show coverage you read — in a glossy magazine, on a website, in an app — may be a little different.
Agency guidelines, as well as the F.T.C. Act, require the “clear and conspicuous disclosure” of connections “that might affect the weight or credibility that consumers give an endorsement.” Such a connection could be a result of, the guidelines say, “a business or family relationship, monetary payment or the gift of a free product.”
In recent years, for example, the trade commission has targeted Cole Haan for a Pinterest contest that asked users to create boards using Cole Haan shoe images and the hashtag #WanderingSole in exchange for a chance to win a $1,000 shopping spree. It charged Lord & Taylor with deceiving consumers by paying for “native ads” — an industry term for advertising that matches the look of adjacent editorial content — including Instagram posts by fashion influencers and what the agency called “a seemingly objective article” and Instagram post by the publication Nylon.
Most recently, the F.T.C. sent more than 90 letters to fashion brands, celebrities and influencers warning about what it called undisclosed sponsored content, the first time it had taken such a step.
But what about the little-discussed but common practice of fashion brands footing the bill for select publications and influencers to attend and cover preseason collections, also called the resort or cruise collections, which are often held in exotic locales like Havana and Blenheim Palace in England?
Fashion houses including Louis Vuitton, Gucci, Dior and Chanel often underwrite the cost of the trips for top customers and critics, whose publications might not otherwise approve the expense to cover what is essentially a 20-minute show (especially in this age of shrinking editorial budgets).
On one level, such sponsorship makes the coverage possible — thus facilitating a reader service. But it casts a possible shadow over the coverage’s objectivity. And therein lies the problem.
Mary K. Engle, the F.T.C.’s associate director for advertising practices, said the agency does not comment on specific situations, but “if there are connections or financial relationships or someone got something for free, that should be disclosed if it’s not otherwise clear from the context of the communication.”
A quick scan of recent reviews and related coverage in glossy magazines and on the web of the last round of extravaganzas, which dotted the month of May and were held from Paris to California and Kyoto, included few, if any mentions of such arrangements. That suggests disclosures were either not necessary, because the magazines paid for their editors to attend, or were simply not considered important.
Which was it? No one will say.
Representatives for Prada and Gucci declined to comment and Condé Nast — parent to Vogue, W and Glamour magazines — refused to specify whether it paid for employees’ travel or allows them to accept free trips.
Chanel and the luxury giant LVMH Moët Hennessy Louis Vuitton did not respond to requests for comment, nor did InStyle, V Magazine or Hearst Communications, which owns Harper’s Bazaar.
One fashion director who asked to remain anonymous because she was not authorized to speak on the matter said that when she is invited on such trips, she tells the brands she would be happy to go but she can’t promise any coverage in return.
European and British governments do not have the exact same guidelines as the United States, but the London-based digital magazine Business of Fashion recently began to disclose at least some of its brand-sponsored travel and accommodations, something it previously did not do. The site has updated some reviews, including its coverage of Chanel’s resort 2017 show in Cuba, to say the critics were “guests” of the brands and added disclosures at the end of some of its cruise 2018 reviews.
As to why it has changed its practice, the site’s founder and editor-in-chief, Imran Amed, said it “aims to disclose any paid travel associated with a given story in order to be transparent with our community.”
(Historically The New York Times does not accept free travel or accommodations, nor does Women’s Wear Daily, The Washington Post or The Wall Street Journal, among other publications.)
But not all disclosures are created equal. For publications or sites to inform readers properly, Ms. Engle said that the industry practice of placing disclosures at the end of an article (if at all) “is unlikely to be, or less likely to be sufficient, because consumers might not read to the end. You need that disclosure before you are getting the rest of the information. You want it as you are processing the information, so you can know, ‘O.K., this is the deal.’”
Leading the fashion pack in light of the F.T.C.’s most recent enforcement actions is Bryan Grey Yambao, the blogger and influencer better known as BryanBoy, who tweeted in late April: “The resort shows are coming up next month. Who’s disclosing what? I’m disclosing that Prada, Vuitton and Gucci will subsidize my travel.”
Mr. Yambao, who routinely includes these admissions in his sponsored posts and has not been on the receiving end of an F.T.C. letter, said his readers have responded well.
“A lot of my followers appreciate the disclosures,” he said. “They are thankful that I disclose, especially because there are very few influencers who follow the rules.”
So transparency, rather than raising questions of potential bias, might actually dispel them.
Either way, it would be a new look.