Keeping a check on what children see
15 October 2004
We all see hundreds of advertising messages every day. While adults can make discerning judgements about ads, children may be more susceptible. Yet few people outside the advertising industry will be aware that the CAP Code contains specific rules to help to protect children from being misled or exploited by non-broadcast ads. The rules state, amongst other requirements, that advertisements targeted at children should not:
- Contain anything likely to result in their physical, mental or moral harm
- Exploit their credulity, loyalty, vulnerability or lack of experience.
- Make them feel inferior or unpopular for not buying the advertised product
- Encourage them to make a nuisance of themselves.
In July 2003, the ASA assessed a sample of nearly 900 non-broadcast ads aimed at children. The survey revealed a high compliance rate with the CAP Code's requirements, with only seven of the promotions within the sample size breaching the advertising industry's code of practice.
The ASA has also been listening directly to parents' concerns. When a mother, whose young son had spotted a promotion for a Beyblade toy on the back of a Kellogg's cereal packet, complained to the ASA that there was no toy inside, the ASA pursued her complaint. Kelloggs explained that the words '8 to collect inside special packs' appeared on smaller cereal boxes but the toys were only available inside larger packets that had the words 'Free Inside' printed on them. Despite Kellogg's arguments, the ASA Council concluded that the promotion was misleading, implying that the smaller packs also contained the Beyblade toy.
Another complaint, from a father, focused on promotional postcards sent to schools by Letts Educational. The postcards stated: "I AM A WIMP" and "I AM A BIG WUSS" and instructed pupils to stick them on the backs of friends who didn't "have the bottle for the Letts challenge". The ASA upheld the complaint that the postcards were irresponsible and might encourage bullying.
The ASA Chairman, Lord Borrie, Q.C restated the ASA's commitment to ensuring that all companies abide by the advertising industry's code of practice. "We have moved quickly to respond to public concerns about advertising to children. The impact of our rulings extends beyond the individual advertiser and we will not shy away from tackling an entire industry sector to ensure compliance with the Code," he said.
Related Codes:
- 47.1 For the purposes of the Code, a child is someone under 16. The way in which children perceive and react to marketing communications is influenced by their age, experience and the context in which the message is delivered; marketing communications that are acceptable for young teenagers will not necessarily be acceptable for young children. The ASA will take these factors into account when assessing marketing communications.
- 47.2 Marketing communications addressed to, targeted at or featuring children should contain nothing that is likely to result in their physical, mental or moral harm:
- a) they should not be encouraged to enter strange places or talk to strangers. Care is needed when they are asked to make collections, enter schemes or gather labels, wrappers, coupons and the like
- b) they should not be shown in hazardous situations or behaving dangerously in the home or outside except to promote safety. Children should not be shown unattended in street scenes unless they are old enough to take responsibility for their own safety. Pedestrians and cyclists should be seen to observe the Highway Code
- c) they should not be shown using or in close proximity to dangerous substances or equipment without direct adult supervision. Examples include matches, petrol, certain medicines and household substances as well as certain electrical appliances and machinery, including agricultural equipment
- d) they should not be encouraged to copy any practice that might be unsafe for a child.
- 47.3 Marketing communications addressed to, targeted at or featuring children should not exploit their credulity, loyalty, vulnerability or lack of experience:
- a) they should not be made to feel inferior or unpopular for not buying the advertised product
- b) they should not be made to feel that they are lacking in courage, duty or loyalty if they do not buy or do not encourage others to buy a particular product
- c) it should be made easy for them to judge the size, characteristics and performance of any product advertised and to distinguish between real-life situations and fantasy
- d) adult permission should be obtained before they are committed to purchasing complex and costly products.
- 47.4 Marketing communications addressed to or targeted at children:
- a) should not actively encourage them to make a nuisance of themselves to parents or others and should not undermine parental authority
- b) should not make a direct appeal to purchase unless the product is one that would be likely to interest children and that they could reasonably afford. Distance selling marketers should take care when using youth media not to promote products that are unsuitable for children
- c) should not exaggerate what is attainable by an ordinary child using the product being marketed
- d) should not actively encourage them to eat or drink at or near bedtime, to eat frequently throughout the day or to replace main meals with confectionery or snack foods. This clause relates to ads that appeared before 1 July 2007. For ads that appeared after that date clause 47.7e applies.
- e) should not exploit their susceptibility to charitable appeals and should explain the extent to which their participation will help in any charity-linked promotions.
This clause has been updated to conform to the Consumer Protection from Unfair Trading Regulations 2008. This clause does not apply to marketing communications that appear after 24 June 2008. See clause 47.12
- 47.5 Promotions addressed to or targeted at children:
- a) should not encourage excessive purchases in order to participate
- b) should make clear that adult permission is required if prizes and incentives might cause conflict. Examples include animals, bicycles, tickets for outings, concerts and holidays
- c) should clearly explain the number and type of any additional proofs of purchase needed to participate
- d) should contain a prominent closing date
- e) should not exaggerate the value of prizes or the chances of winning them.
This clause has been updated to conform to the Consumer Protection from Unfair Trading Regulations 2008. This clause does not apply to marketing communications that appear after 24 June 2008. See clause 47.13.