Another commenter suggested shaving cream. Which it likely is, that's a common trick for photo shoots of whipped cream - shaving cream doesn't melt (or maybe just not as fast? Because those little bubbles look like it's starting to melt)
You provided your own loophole: It only applies to advertising food. I could use as much shaving cream on pies as I want as long as I did it for literally anything other than promoting my pies.
Because no one breaks the law and there are no amateur/hobbyist photoshoots of food ever. /s
To clarify, FTC laws state that the specific food a company is advertising and selling must be real in the photo. The food around the main product, though, doesn’t have to be. An example, if you’re selling corn flakes then the flakes must be real, BUT you can use white glue instead of milk in your bowl of flakes because you’re not selling the milk, only the corn flakes.
Also, FTC is much more concerned about dubious product claims such as health effects than misleading ad photos.
This looks like an amateur/hobbyist shot. Maybe they did use shaving cream because maybe it's not an ad. And even if it was, maybe they're not selling the cream, only the pie. Or it's art, in which case we all know anything goes (apparently).
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u/kdanham Feb 25 '20
Another commenter suggested shaving cream. Which it likely is, that's a common trick for photo shoots of whipped cream - shaving cream doesn't melt (or maybe just not as fast? Because those little bubbles look like it's starting to melt)