Hidden Sales Promotion Problem
15 October 2004
A survey by the Advertising Standards Authority (ASA) has revealed that a quarter of on-pack sales promotions may not be administered in line with the British Code of Advertising, Sales Promotion and Direct Marketing (the CAP Code).
The On-Pack Sales Promotions Survey 2003, which is the first survey of its kind, looked at just under 300 on-pack sales promotions that appeared in UK supermarkets between February and July 2003. Both the content and administration of the promotions was assessed for CAP conformity.
For the administration assessment, a smaller sub-group of promotions, all of whose closing dates had already passed, was randomly selected from the sample. Worryingly, the administration of only 74% of them was in line with the CAP Code's requirements. The problematic promotions fell foul of the rules because the promoters were either unable to demonstrate that prize draws had been independently supervised or that the fair and random distribution of instant win prizes had been independently verified.
However, when the whole sample group was assessed for content breaches, just 16 promotions fell foul of CAP Code; an overall compliance rate of 94%. None of the identified problematic promotions had prompted complaints to the ASA.
The survey looked at a range of different types of on-pack sales promotions, but only three techniques produced CAP Code breaches - premium promotions (where all consumers get the same gift, benefit or item irrespective of chance); prize draws and
competitions; and instant win promotions. Premium promotions appear to be the most popular type of sales promotions and formed 60% of the promotions that were examined. Prize draws and competitions formed 24% of the survey promotions. However, though forming only 16% of the sample survey, instant win sales promotions constituted half of all the breaches that were identified by the ASA Compliance team.
The CAP Code compliance rates for the three types of sales promotions were: 97% for premium promotions, 94% for prize draws and competitions and 83% for instant win promotions. The problems that were identified were minor errors rather than fundamental flaws in the design and content of the promotions.
Commenting on the survey's findings, Christopher Graham, Director General of the ASA, said: "Sales promotions are designed to give advertisers an advantage by increasing the attractiveness of their goods to consumers. This survey shows that whilst compliance within this sector is high, promoters need to work harder to ensure that they run their promotions in line with the CAP Code's requirements, particularly when they are carrying out the administrative side of their promotions. Promoters should not be inclined to excuse themselves from breaches of the CAP Code because no-one complains. Our compliance team will continue to monitor this area to identify the problems and encourage good practice."
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