If you rank your own product #1 in “best of” listicles, it’s not just a search-quality issue — it may violate FTC rules that took effect in October 2024.
Driving the news. As Lily Ray noted on LinkedIn, the FTC’s Consumer Review Rule (16 CFR Part 465) prohibits several deceptive practices tied to reviews and testimonials, including:
- Presenting company-controlled content as independent reviews.
- Publishing reviews of products or services never actually used.
- Attributing reviews to people who didn’t write them.
Penalties can reach up to $53,088 per violation, and each page may count separately. Ray also shared a reference table she generated with the help of Claude:
Why now. “Best X” and “Top 10 Y” listicles have surged as a GEO tactic over the past couple of years. These pages often perform well in search and increasingly influence AI-generated answers.
The backstory. Before the rule was formalized, Ray said at least one company faced legal action for publishing hundreds of “best of” pages that:
- Ranked its own services #1.
- Included fabricated competitor reviews.
- Used fake reviews on third-party platforms.
The Better Business Bureau later censured the company for unsubstantiated claims.
What’s happening. Many modern listicles follow a similar pattern:
- A brand publishes a “best tools” list.
- Includes competitors it hasn’t tested.
- Uses subjective or invented scoring systems.
- Ranks itself #1.
These listicles may imply independence or firsthand evaluation when neither exists.
The nuance. You can publish comparison content that includes your own product. However, based on FTC guidance, risk increases when:
- You imply objectivity, but promote your own product.
- You present reviews not based on real experience.
- You fail to clearly disclose material relationships.
What Google is saying. Google is aware of the low-quality listicle trend. In a statement to The Verge, a Google spokesperson said the company applies protections against manipulation in Search and Gemini, and reiterated its guidance: create content for people and ensure it’s understandable to search systems.
Why we care. What has worked as a visibility tactic may carry risk on two fronts — regulators and a potential Google Search algorithm change. That means this popular GEO tactic could decline quickly as its effectiveness drops.
Caveat. I’m not a lawyer. Consult your own legal counsel if you’re concerned about using this tactic.
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