ASA Adjudication on Boots Group plc

Ad

A TV ad, for Boots Soltan sun cream, showed children with very tanned skin lying still on a beach, sunbathing. A voiceover stated "UVA exposure from the sun causes long term skin damage. And if you knew that more than half the annual exposure your child receives could happen during their summer holidays, you'd protect them with Boots Soltan, the number one range of children's five star UVA protection." The ad then showed a selection of Boots Soltan products; onscreen text stated "The UK's No1 range of children's 5 star UVA protection."

Issue

The complainants, who pointed out that children should cover up in the sun or stay out of the sun instead of relying solely on sun cream, thought the ad was misleading and could cause harm to childrens health, because it suggested that it was safe to expose childrens skin to the sun if they were wearing sun cream.

BCAP TV Code

Response

Boots said they intended the ad to educate consumers on the importance of childrens safety in the sun and believed the ad had achieved the desired result of provoking debate about the dangers of sun exposure and the necessity of sun protection, particularly for children.

Boots explained that the ad had an eerie, surreal atmosphere and portrayed an unnatural, unrealistic scene of a beach full of children who were acting like adults.  Instead of running, playing and laughing, the children were silent, still and sunbathing.  They said they intended to dramatise the danger of sun exposure by showing children at risk, thereby shocking viewers into realising the need to protect children from the sun.  They said the voiceover reinforced the impression that the depicted behaviour was not normal or safe.

Boots said the ad promoted Soltan as one method of protecting children from the sun; it did not suggest that using Soltan was the only way to prevent long-term skin damage.  They said the advertised product stated on its packaging For optimum performance apply liberally 15 minutes before going in the sun and again immediately upon sun exposure.  Reapply every 1-2 hours and always after swimming and towelling.  Avoid sun between 11 and 3.  Seek shade and use clothing to limit sun exposure.  They pointed out that the ad did not show Soltan being used or applied and believed it did not imply Soltan would protect children in the sun in the unlikely event of them sunbathing in the manner shown.

Boots said they tested consumers reactions to the ad before it was broadcast.  They said the consumers had understood the ads message that children needed protecting from the sun and had not misinterpreted the ad as implying Boots endorsed the practice of children sunbathing or as implying it was safe for children to sunbathe if they were wearing Soltan sun cream.

The Broadcast Advertising Clearance Centre (BACC) said the ad had a quietly sinister tone and showed children behaving unnaturally, mimicking adults who over-exposed themselves to the sun.  They said the ad delivered a cautionary message and made clear that sun exposure of the type depicted in the ad should be avoided; they pointed out that the voiceover stated "UVA exposure from the sun causes long-term skin damage.  The BACC said the ad suggested that children needed adequate sun protection, particularly during their summer holidays, and that Soltan products could provide that protection.  They believed the ad did not imply Soltan could be used to prolong sun exposure.

Assessment

Complaints upheld

The ASA considered that viewers were likely to realise that the depicted behaviour was unrealistic and were unlikely to infer that it was safe or natural for children to sunbathe in the manner shown.  We also considered that viewers were likely to realise that the ad was conveying a serious message that children needed to be protected from the sun.  We noted, however, the voiceover referred to UVA exposure causing skin damage and stated " … if you knew that more than half the annual exposure your child receives could happen during their summer holidays, you'd protect them with Boots Soltan, the number one range of children's five star UVA protection."  We considered that the ad suggested that Soltan offered children full protection from the sun's harmful effects and that it was safe for children to be out in the sun if they were wearing the advertised product.  We understood that that implication was misleading, because it was equally or more important for children to cover up in the sun or avoid the sun.  We concluded that the ad gave a misleading impression of the capabilities and performance of the advertised product and could lead to harm to children's health.

The ad breached CAP (Broadcast) TV Advertising Standards Code rules 5.1 (Misleading advertising), 5.2.2 (Implications), 6.7 (Health and safety) and 7.3.2 (Physical harm).

Action

The advertising must not be broadcast again in its current form.

Adjudication of the ASA Council (Broadcast)