Summary of Council decision:
Two issues were investigated, both of which were Not upheld.
An animated cinema ad, shown before the U-rated film 'Monster's University' at 4:30 pm, featured an equity brand character holding a surfboard at the top of a long waterslide. He said "Chip the Wolf here; delicious Cookie Crisp there" as the camera panned out to the bottom of the waterslide, where two children were eating bowls of the cereal. One of the children said "Mmmm" as they ate a spoonful. The camera panned back to Chip who said "Cookie Crisp, looks like chocolate chip cookies and tastes like them too" as a thought-bubble showed a close-up of the cereal being poured from the pack, milk being added, and a spoonful of the cereal. Chip licked his lips and looked through binoculars towards the two children, and exclaimed "But! Now has even more chips? So I'll do even more to get them". From the perspective of looking through the binoculars, the children could be seen eating the cereal on either side of the cereal pack. Text on the pack stated "NOW WITH MORE CHOCOLATEY CHIPS!". Chip jumped on the surfboard and launched down the waterslide. At the bottom his surfboard sprouted wings and he grabbed the cereal pack from the children, shouting "The Cookie Crisp is mine!". He crashed into a tree and the cereal box emptied onto the children below, who collected the cereal in their bowls and took more bites. One said "Yeah!". Chip said "Cookie Crisp, now with more chips than ever before". Large on-screen text stated "COOKIE CRISP NOW WITH MORE CHIPS". Small on-screen text said "More than 35% increase in chip content".
The complainant challenged whether the ad:
1. condoned or encouraged poor nutritional habits or an unhealthy lifestyle in children; and
2. disparaged good dietary practice.
1. Cereal Partners UK said dietary advice from the Food Standards Agency (FSA), Department of Health (DH), NHS, Public Health England and the British Dietetic Association highlighted the importance of breakfast as a meal in a healthy balanced diet, and the importance of wholegrains. They said that, as a breakfast cereal, Cookie Crisp represented an important element in maintaining a balanced diet and consequently provided a positive contribution to good dietary health and encouraged good nutritional habits. They referred to specific advice from the FSA and the NHS that wholegrain cereals were a good source of fibre, and that they could form part of a healthy balanced diet.
Cereal Partners UK said the National Diet and Nutrition Survey of 4- to 18-year-olds in the UK showed evidence of an inadequate micronutrient intake, which was less prevalent when children consumed fortified cereal. Cookie Crisp was fortified with vitamins and minerals and contained whole grains. A recommended serving contributed 9% of a child's Guideline Daily Allowance (GDA) of sugar, and 11% of their fibre. The micronutrients provided anywhere from 18% to 30% of the Recommended Daily Allowance (RDA) of nine vitamins and minerals. Adding milk, as most consumers did, increased the micronutrient intake of important minerals and vitamins. They said the product had been reformulated and for the purposes of adding more chips, the sugar in the cereal had been reduced by 26.5%. They said that the 'chips' in the cereal were not chocolate in the generally accepted confectionary sense, but were visual representations of 'chocolate chips' that might be found in a cookie.
Cereal Partners UK added that nutritional habits and a healthy lifestyle were a combination of the foods chosen and the frequency with which they were consumed; they were not related to a single food source. In the ad, the characters were sat at a table where the cereal was positioned with milk and fruit, which indicated the fact the product was intended to be part of a balanced diet and healthy lifestyle. The characters in the ad were also seen to be active, so that they did not represent a sedentary lifestyle.
Cereal Partners UK said they had taken steps to ensure that children's exposure to the ad was regulated. An agency had provided them with information about expected audiences for a range of family films, and they had scheduled the ad to be screened only before films where less than 35% of the audience were expected to be children under 12 years of age. The information from the agency showed that the expected audience profile for ‘Monsters University’ would be 18% children under 12 years of age.
2. Cereal Partners UK said the ad promoted, rather than disparaged, positive dietary practices, as recommended by health experts including the FSA, DH and NHS. They said the events in the ad unfolded at one meal occasion and so did not encourage frequent consumption. The ad suggested the cereal was a breakfast option but there was no suggestion that it should be consumed throughout the day or more than once a day. Furthermore, the characters were shown consuming no more than three spoonfuls of the cereal from a reasonably-sized cereal bowl. Cereal Partners UK said they suggested a portion size of 30 g, which was a common serving size for a cereal of that type and was in line with the European Breakfast Cereal Trade Association guidance on recommended portion sizes.
Cereal Partners UK said the ad used animated computer-generated imagery to produce a fantasy setting. They considered most children would understand the wolf character surfing down a water slide on a surfboard that turned into a flying machine, and Cookie Crisps falling from the sky to be caught by the children in their cereal bowls, was not reality and could not be suggested to encourage excessive consumption of the product.
1. & 2. Not upheld
The ASA noted the information relating to the expected audience profile for the ad. We noted the CAP Code defined children as persons aged under 16 years of age, but that the audience profile information did not provide data relating to children aged 12 to 15. We noted Cereal Partners UK believed they had taken steps to ensure that children's exposure to the ad was limited, because it was expected that children under 12 would form only 18% of the cinema audience for the film. We considered, however, that in placing the ad before screenings of U-rated films, the ad had been specifically targeted to films which would have the highest percentage of young children in the audience compared to films with higher age-ratings.
We considered it likely that the film 'Monsters University' would have had particular appeal to children, and therefore that children under 16 would have formed a significant proportion of the cinema audience, particularly in relation to the screening seen by the complainant which was at 4:30 pm during a school holiday. We considered the cartoon-style and comedic storyline would be of appeal to children, as would the description of the product as "delicious", its visual similarity to chocolate chip cookies, and the emphasis on the product containing "even more chips". We considered the ad, and the advertised product, would be of particular appeal to children.
We acknowledged the documentation provided by the advertiser demonstrated that health experts highlighted the importance of eating breakfast for a healthy diet, and that fortified and wholegrain cereals provided a range of nutrients and fibre which contributed to a healthy diet. We also noted that one of the documents, a fact sheet about sugar produced by the British Dietetic Association, stated "As sugar contains calories but few nutrients, eating too much sugar and foods and drinks rich in added sugars, instead of other foods, may make your diet less nutritious", and later stated that products that contained more than 15 g of sugars per 100 g were considered to have a high sugar content. We noted Cookie Crisp contained 24.5 g of sugar per 100 g and therefore, whilst it contained ingredients which contributed to a healthy diet, it also contained a relatively high amount of sugar, a substance which health experts advised should be eaten in moderation.
Notwithstanding that we considered the ad and the product were likely to appeal to children, we considered the ad did not include any content which condoned or encouraged poor nutritional habits or an unhealthy lifestyle, or disparaged good dietary practice. The ad included brief shots of the children eating the cereal, and although they caught some in their bowls when it fell from the sky at the end of the ad, we considered that was not sufficient to condone or encourage frequent or excessive consumption of the product or to suggest that an inactive or sedentary lifestyle was better than physical activity. We concluded the ad did not breach the Code on those points.
We investigated the ad under CAP Code (Edition 12) rules 15.11 15.11 Marketing communications must not condone or encourage poor nutritional habits or an unhealthy lifestyle in children. and 15.12 15.12 Marketing communications must not disparage good dietary practice or the selection of options, such as fresh fruit and fresh vegetables, that accepted dietary opinion recommends should form part of the average diet. (Diet and Lifestyle), but did not find it in breach.
No further action necessary.