We are advising marketers to ensure they make clear when online content is marketing material.

A basic principle of the CAP Code is that marketing communications “must be obviously identifiable as such” (rule 2.1).

Marketers are encouraged to review online content they have published or intend to publish. If there is any doubt about whether children will recognise the commercial intent, we strongly advises marketers to make it clear that the content or parts of the content constitute a marketing communication, for example, by labelling the content in a clear and timely manner.

This interim advice follows our established position on identifying marketing communications in different media and also recent rulings by the ASA relating to online media.

It also comes on the back of our response to the review of the literature on online food and drink marketing to children carried out by Family Kids & Youth.

The review examined how children interact with immersive online marketing across all sectors and highlighted some concerns about their critical understanding of this content. Advergames are one example of immersive content but it could also cover brand websites with different types of interactive content, content on social networks, vlogs or other forms of contextually targeted branded content.

We have committed to looking into the research identified by the review in more detail and publishing new guidance in Q3 2015 to help marketers put in place steps to ensure that children are able to recognise marketing communications within different types of immersive content.

Guidance on advertising food to children is available via our website.

If you have any questions or require advice on this issue, please contact Copy Advice.


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