As the evenings close in and Autumn approaches, it’s nearly that time of year for bonfires, sparklers, pumpkins, witches and ghouls. But don’t let a complaint about your ad give you a paranormal fright! Here are our top tips on keeping your ads compliant and zombie-tight.
Don’t overdo the boo
Although children love to don their eeriest costumes at Halloween, marketers should shield young eyes from unsuitable horror and supernatural themed content. Careful placement and targeting is the name of the child-friendly game - as well thinking about the levels of jeopardy, gore and realism shown in such ads.
There’s been a frightful crop of ASA rulings about ads and trailers for spooky films this year! An image in poster ad for The Mummy film was considered a realistic depiction of a dead child – it featured a large, close-up image of an ashen and lifeless face draped in a shroud. The ad’s placement in an untargeted medium on the London underground network was deemed unsuitable where it might be seen by young children. On the other hand, TV and poster ads for the film They Will Kill You didn’t go too far. The ASA considered the ads were not excessively graphic or gory for the audience, and most violence in action scenes in the TV ads was implied rather than shown.
Although more sci-fi than horror, another film ad for Predator Badlands with violent scenes was ruled too frightening and potentially disturbing for young children in out of home. One scene showed an alien-like character holding up the top half of a human-looking figure, with gory imagery of its severed torso and exposed spine. Close-up shots of a character’s face, which had a distorted structure without a nose, sharp fangs, reptilian-like skin, and non-human eyes staring directly into the camera, also contributed towards the ad being likely to scare children.
Kids are usually the main concern, but ads must also not cross to the ‘other’ side of the compliance line - by causing excessive fear and distress to adult and general audiences too. The level of jeopardy in a VOD ad for horror film Evil Dead Rise in 2023, with tense, jumpy and gory scenes and sound effects, was considered unduly frightening even for general viewing by adults. The ASA ruled the ad needed more careful targeting during programming in which its scary content would likely be more anticipated.
Double, double your toil and trouble… with care on LHF products
With kids taking to the streets for trick or treating across the land, sweet and sugary treats are certainly a big theme around Halloween! This year, marketers should ‘beware’ of the relatively new Less Healthy Food (LHF) restrictions that now apply to paid-for ads on the internet, and ads on certain TV and on-demand programme services. The HFSS rules also still generally apply across all mediums.
The first set of rulings under the new rules prohibiting ads for LHF products in certain mediums have recently been published by the ASA. Upheld complaints have included ads depicting tubs of Swizzels Sweets, and Peanut M&Ms andan ad featuring a Thornton’s chocolate egg
Back to the bare bones of the Codes
The Ad Codes take safety and social responsibility seriously, especially when kids are involved. Ads must not generally condone or encourage an unsafe practice – like holding lit fireworks - and linking handling explosives with the consumption alcohol in ads is likely to be a no-no. Although it’s the season for fireworks, bonfires and creepy decorations, children in ads shouldn’t be shown in hazardous situations or behaving dangerously, or around dangerous equipment or substances without adult supervision.
It’s of ‘grave’ importance to get the basics right. Halloween themes and outfits can be lots of fun, but marketers should keep in mind where there’s potential for harm and offence. For example, the negative portrayal of serious mental health illnesses is likely to cause offence. A complaint against a website listing for a Halloween costume titled “Adult Skitzo” was upheld as it was likely to cause serious or widespread offence.
Summon up some advice…
Got an ad that might be a bit too spooky? Let us exorcise your compliance concerns. Whatever the season, our Copy Advice team is on hand to provide bespoke advice on non-broadcast ads.
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