An ad for toys based on characters from the video game "Bendy and the Ink Machine" was seen on Cartoon Network throughout the day on 23 August, on Disney XD on 26 August, and on Pop Max mid-morning during "Pokemon" on 30 August. The ad featured different characters on a jerky, sepia-toned, cartoon-like background depicting a warehouse. Some rooms shown had writing and ink on the wall. Jaunty, old-fashioned music played and a voice-over stated, "It's Bendy and the Ink Machine! Bendy, Boris, Alice, er, Bendy?" as each character was shown, including a version of the "Bendy" character with horns and its face covered in ink. The voice- over continued "Say, now these are cute! Get your own Bendy and the Ink Machine action figures and plush toys today".
Three complainants, who understood the characters were from a 12+ rated video game, believed they were therefore unsuitable to be advertised on children's TV channels. Two of the complainants also said their children had found the ad creepy and challenged whether it had been inappropriately scheduled.
PhatMojo said that Clearcast had reviewed the ad and cleared if for use without restrictions. However, their UK distributor had indicated that the ad was no longer being aired on children’s TV.
Clearcast said they felt that the ad did not contain anything that would warrant a scheduling restriction. The tone and overall impression of the ad was not scary, dark or creepy. On the contrary, the voice-over and music were both jolly, upbeat and light -hearted, and in no way resembled something that could scare or cause harm to a child. The ad clearly showed soft toys being handled by children, all of which had smiley and faces resembling children’s cartoon characters. They felt that none of the faces were in any way frightening. The ad itself made no reference to downloading or playing the “Bendy and the Ink Machine” video game, and being a spin-off toy product from an age-rated video game would have no bearing on restrictions or presentation codes applied by Clearcast. They believed that the age certificate applied to the video game on which the toys were based had no relevance to the TV ad in question.
Turner (Cartoon Network) said that they had adhered to the advice given by Clearcast, which gave no indication that the ad was unsuitable for children of any particular age. They did not believe the ad to be creepy or scary and had received no complaints from viewers.
Disney (Disney XD) said that the ad had been cleared by Clearcast with no restrictions; they had also been reviewed for suitability by their in-house team. They did not feel that the ad was too scary for the Disney XD channel, or that it went beyond the audience expectations of the channel.
Sony (Pop Max) said that all advertising for their UK channels was prepared by an agency that abided by the restrictions applied by Clearcast and felt that the ad was appropriate to be scheduled on Pop Max. However, having now viewed the ad, Sony felt that it did have elements that might be scary to younger children and had asked that it be withdrawn from their channels.
The ad showed several different toys on a cartoon background. The background music was upbeat and the characters were smiling and drawn in a style reminiscent of many children’s cartoons. We acknowledged that some people might consider certain elements of the ad, such as the background and the second “Bendy” character, to give it a spooky tone. However, we did not consider that the images shown were likely to scare or cause distress to children.
We noted the complainants’ concerns that the characters were derived from a video game with a 12+ rating. However, there was no reference to purchasing or playing the game, or any direction on how to do so. We considered that the focus of the ad was on the toys themselves and that it was not inappropriate for those to be advertised to children.
We considered that the content of the ad was unlikely to distress children. Also, because the ad focused on the toys and did not encourage children to download or play the video game, we therefore considered that it had be appropriately scheduled and did not breach the Code.
The ad was investigated under BCAP Code rules
Advertisements must contain nothing that could cause physical, mental, moral or social harm to persons under the age of 18.
(Harm and offence),
Advertisements that are suitable for older children but could distress younger children must be sensitively scheduled (see Section 32: Scheduling).
(Children), 32.1 32.1 Broadcasters must exercise responsible judgement on the scheduling of advertisements and operate internal systems capable of identifying and avoiding unsuitable juxtapositions between advertising material and programmes, especially those that could distress or offend viewers or listeners. and 32.3 32.3 Relevant timing restrictions must be applied to advertisements that, through their content, might harm or distress children of particular ages or that are otherwise unsuitable for them. (Scheduling), but was not found in breach.
No further action required.