No More Kid-ding Around: The Rules of Advertising to Children

With World Children’s Day taking place on 20 November, and Christmas just around the corner, now is a good time to look at the rules on advertising to children. As toys, games and family-focused products dominate advertising in the run-up to Christmas, advertisers should take extra care to ensure their campaigns are responsible, transparent and age appropriate.

Under the CAP Code, a child is anyone under the age of 16 and the rules in Section 5 are designed to protect children from being misled, exploited or harmed by advertising, reflecting wider consumer protection principles but also the unique vulnerabilities of younger audiences.

Be clear and avoid pressure

There is no general ban on advertising to children, but marketers must not directly encourage children to buy products themselves or persuade parents and carers to make purchases on their behalf. Ads should not encourage “pester power” or undermine parental authority.

Children’s limited experience means marketers must take particular care not to exploit their credulity, loyalty, vulnerability or desire to fit in. Products can be shown in a positive light, but ads should not suggest that children who do not own them are unpopular, unsuccessful or somehow inferior to their peers.

Make sure it’s child friendly

Advertising aimed at or featuring children must not contain anything likely to cause physical, mental or moral harm. Children should not be encouraged to engage in dangerous behaviour, copy unsafe practices or take unnecessary risks.

Marketers should also consider the potential impact of their advertising on children’s wellbeing and self-esteem. Content that could cause distress, fear or anxiety, or that promotes unhealthy body image expectations, is likely to be considered an issue.

Is ad-ult Supervision Required

With children increasingly spending time on social media, gaming platforms and video-sharing services, audience targeting is more important than ever. Marketers should ensure they understand the audience profile of the media they use and take reasonable steps to prevent campaigns from reaching inappropriate age groups.

Businesses operating online should also be mindful of the ICO’s Children’s Code, which places obligations on digital services likely to be accessed by under-18s, including rules relating to profiling, personalised advertising and the use of children’s data.

Keeping It Age Appropriate

Extra care is required when advertising age-restricted products such as alcohol, gambling services and e-cigarettes. These ads must not target children or have appeal to them. Marketers should avoid youth-oriented themes, imagery or personalities that strongly resonate with under-18s.

Food advertisers should also be aware of the HFSS rules in Section 15. This places restrictions on ads that are high in fat, salt or sugar. In addition to the HFSS rules, new Less healthy food (LHF) rules have come into force. Advertisers should consider both LHF and HFSS rules when ads may be seen by children.

The key principle remains simple: when children may see or engage with advertising, marketers should put their welfare first and ensure campaigns are responsible, transparent and age appropriate.

No More Kid-ding Around: The Rules of Advertising to Children