Ad description
A paid-for YouTube ad for a Domino’s Cadbury Creme Egg cookie product seen during a Minecraft feature on the channel Milo and Chip on 8 March 2025, featured a voiceover that stated, “Domino’s cookies stuffed with a whole Cadbury Creme egg”.
On-screen imagery showed the cookie being broken apart to reveal the egg filling. Domino’s branded lettering stated, “Domino’s COOKIES MADE WITH” featured alongside the Cadbury Creme egg logo.
Issue
The complainant challenged whether the ad was for a product that was high in fat, salt or sugar (HFSS product) and was directed at children through the selection of media or context in which it appeared.
Response
Domino’s Pizza UK & Ireland Ltd t/a Domino’s confirmed that the Domino’s Cookies made with Cadbury Creme Egg was an HFSS product. They said they ensured the ad was not directed at under-16s through the selection of media or the context in which it appeared, and that the campaign followed YouTube’s policy for HFSS products. They also said the ad was only shown to signed-in users, restricted to over-18s, and excluded all YouTube Made for Kids (MFK) channels. They said Google had confirmed the ad did not appear alongside any MFK content and was run from their account that was classified as HFSS.
They said that Minecraft had a broad and ageing audience, with worldwide users under-15 making up less than 21% of its player base. They said that adult viewers, particularly those aged 35–44, made up a significant proportion of Minecraft content viewership on YouTube. They also referenced the “Minecraft Movie”, which they said featured adult humour and marketing targeted at adults.
They acknowledged that the Milo and Chip YouTube channel featured graphics that could appeal to children, but said it had a broad audience and was not specifically aimed at children, and that the channel was not labelled as MFK. They also said the channel included content aimed at older viewers, with references in video titles to themes such as “killing”, “death” and “stalking”.
Google said that they provided advertisers with tools to ensure HFSS product ads were restricted to audiences aged 18 and over. Advertisers could self-declare ads as HFSS, in which case restrictions would apply. They said advertisers remained responsible for complying with relevant legal and regulatory requirements, including the CAP Code, and retained control over ad format, placement, and audience selection.
Assessment
Upheld
The CAP Code stated that HFSS product ads must not be directed at people under 16 years of age through the selection of media or the context in which they appeared. The ad promoted a Cadbury Creme Egg Cookie, which was classified as a product high in fat, salt or sugar (HFSS). The ad was shown in an ad-break during content on a YouTube channel called Milo and Chip, that was dedicated to Minecraft-related content.
Minecraft was a video game where players could explore, build and survive in a world made of blocks. The Ofcom report “Children and Parents: Media Use and Attitudes Report 2025” stated that Minecraft fell within the most popular type of game among children. Although The ASA acknowledged that Minecraft was not exclusively aimed at children, we considered it remained highly popular with under-16s. The game had a broad fanbase that included both children and adults. We acknowledged that a recently released Minecraft film contained content that would appeal to adults. However, we also understood that Minecraft’s enduring popularity meant new, younger players continued to engage with the game and its wider community on social media platforms.
We assessed the specific channel on which the ad appeared. The channel’s branding used cartoon-style illustrations of the main characters. Videos on the channel featured two animated characters in Minecraft block-style; one character was depicted as a boy and the other as a blue bird. The characters were voiced in a manner similar to a children’s cartoon, and we considered the blue bird’s voice to be particularly high-pitched and childlike. The channel showed Minecraft characters exploring virtual environments, and we considered the scenarios, would be likely to appeal to children familiar with the game.
We also assessed the specific content during which the ad was seen. The video titled “Minecraft’s Largest TNT Explosion”. The video exclusively featured Minecraft game imagery and showed the two characters exploring different types and sizes of TNT blocks and the types of explosions they made. We considered the use of Minecraft imagery, in which the characters and blocks were used in the style of the game, would have been appealing to children. We also considered the colours and theme of the programme, creating explosions, was also content that children would find appealing. Finally, the lettering used for text across the video was in the style of bubble-writing, in different bright colours. We considered that this font and colouring was cartoon-like and therefore would have been of appeal to children. Further, the dialogue used throughout the video was in the style of one of the main characters, Milo, who had a high-pitched and child-like voice. The content of the dialogue also featured the phrase “don’t tell me you need to go potty”, which we considered was reminiscent of terminology parents would use with younger children.
We acknowledged that age-based targeting had been applied to the ad to exclude signed-in users under the age of 18. We also understood that the ad had been excluded from YouTube’s MFK content. However, although Milo and Chip was not a MFK channel, those exclusions had proved insufficient to prevent the ad from being seen around videos on the channel, specifically during a Minecraft video.
Because the ad appeared during a video which featured content likely to appeal to children, we considered Domino’s had not taken sufficient care to ensure the HFSS ad was not directed at individuals under the age of 16, through the medium in which it appeared. We therefore concluded that the ad had breached the Code.
The ad breached CAP Code (Edition 12) rule 15.18 (Food, food supplements and associated health and nutrition claims).
Action
We told Dominos UK & Ireland Ltd t/a Domino’s to ensure their ads were appropriately targeted and that ads that were unsuitable for viewing by children did not appear in media that was likely to appeal to children.
