The Media Rating Council’s newly-released guidelines require that sponsored user-generated content (UGC) appearing on a social media platform should be clearly labeled to distinguish between what is paid advertising and what is organic. And paid UGC should not be counted in reported measurement.

The Media Rating Council (MRC) unveiled its Social Media Measurement Guidelines yesterday to establish a detailed set of methods and common practices for organizations that measure social media activity.

The preliminary guidelines, which further the requirement of clearly labeling paid user-generated content (UGC), say that paid UGC that is valid but should be disclosed and segregated in reporting from activity associated with branded content. In addition, paid UGC should not be counted in reported measurement, according to the guidelines.

Although the guidelines aim to further the concept of clearly labeling, they don't specify what type of paid UGC is "properly disclosed" or "clearly labeled." For example, is the #CorrectiveAd drug post below from Kim Kardashian aligned with the new guidelines?

#CorrectiveAd I guess you saw the attention my last #morningsickness post received. The FDA has told Duchesnay, Inc., that my last post about Diclegis (doxylamine succinate and pyridoxine HCl) was incomplete because it did not include any risk information or important limitations of use for Diclegis. A link to this information accompanied the post, but this didn’t meet FDA requirements. So, I’m re-posting and sharing this important information about Diclegis. For US Residents Only. Diclegis is a prescription medicine used to treat nausea and vomiting of pregnancy in women who have not improved with change in diet or other non-medicine treatments. Limitation of Use: Diclegis has not been studied in women with hyperemesis gravidarum. Important Safety Information Do not take Diclegis if you are allergic to doxylamine succinate, other ethanolamine derivative antihistamines, pyridoxine hydrochloride or any (Read more...) the ingredients in Diclegis. You should also not take Diclegis in combination with medicines called monoamine oxidase inhibitors (MAOIs), as these medicines can intensify and prolong the adverse CNS effects of Diclegis. The most common side effect of Diclegis is drowsiness. Do not drive, operate heavy machinery, or other activities that need your full attention unless your healthcare provider says that you may do so. Do not drink alcohol, or take other central nervous system depressants such as cough and cold medicines, certain pain medicines, and medicines that help you sleep while you take Diclegis. Severe drowsiness can happen or become worse causing falls or accidents. Tell your healthcare provider about all of your medical conditions, including if you are breastfeeding or plan to breastfeed. Diclegis can pass into your breast milk and may harm your baby. You should not breastfeed while using Diclegis. Additional safety information can be found at or Duchesnay USA encourages you to report negative side effects of prescription drugs to the FDA. Visit or call 1-800-FDA-1088.

A photo posted by Kim Kardashian West (@kimkardashian) on

Ron Pinelli Jr., vice president of digital research and standards at the MRC, doesn't provide a "yes or no" answer, explaining that the concept of clearly labeling gets complex depending on the source of the original authorship.

"The Social Media Measurement Guidelines further [the concept of clearly labeling] by encouraging clear labeling of sponsored or paid UGC, but this might not always occur. Measurers seeking to comply with the guidelines should develop mechanisms to track and report sponsored or paid UGC separately from organic content to the extent possible." he says. "Furthermore, if such activity is intended to be invalid [this is not the case in Kim Kardashian's post above] for the sake of inflating measurement, referred to as 'shilling' in the document, measurers should develop techniques to detect and remove such activity."

Noah Mallin, head of social at agency MEC's North America operations, doesn't give a definitive answer either, though he notes that there's a whole other level of compliance that is necessary with highly regulated industries. Particularly with the Food and Drug Administration (FDA), the guidelines can be restrictive and tricky.

"Labeling is an open industry issue. Our point of view has always been that if a celebrity is compensated on behalf of a brand to post something, the post has to disclose such relationship," he says. "For example, the celebrity can use a hashtag #endorsement or write a description like ‘the company I work with...' I think a basic question we can ask is, would users understand that the person who is sharing product information has the relationship with the company that owns the product?"

As an advertiser, Mallin thinks that it's challenging to have a consistent measurement across different social media platforms, but he believes that the release of the guidelines is a good sign.

"Social is made of different networks that have their own way of measuring, so I think setting up an industry standard is good first step. It definitely helps demystify social for our clients," he says.

The guidelines are available for public comment until October 15. After that, the working group - which includes American Association of Advertising Agencies (4A's), the Interactive Advertising Bureau (IAB) and the Word of Mouth Marketing Association - will address comments and issue a final version.

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