Marketing to children: Latest Advertising Standards Authority guidance
In June the Advertising Standards Authority issued guidance on enhanced disclosures in children’s marketing, to ensure that children are aware that a communication is an advertisement.
Under Section 2 of the CAP Code, all advertising needs to be obviously identifiable as such, which can sometimes be more difficult when directed to younger children. The ASA released the guidance in order to explain how the rules apply in relation to children, particularly those under the age of 12.
The ASA outlines the fact that children begin to recognise marketing at a very young age and have reasonably well-developed levels of critical understanding from the age of around 8 years. By the age of 12, children approach adult levels of critical understanding. However, younger children still struggle with significantly integrated and highly immersive marketing in online environments.
The ASA define a ‘highly immersive’ marketing communication as one which features prolonged or in-depth interactivity, mainly game play or narrative such as a story in audio-visual context.
They define a ‘significantly integrated’ marketing communication as being visually or otherwise integrated into the surrounding editorial content or context, such as a display ad that looks as if it is part of the surrounding content. The usual separations between advertising and other content – spatial and/or thematic – are absent.
Examples include, but are not limited to;
- paid and controlled product endorsements by an influencer (e.g. a vlogger or blogger);
- branded video content on third party sites (where the video has the effect of promoting products or a brand);
- marketing communications appearing in virtual online worlds and other games;
- display advertising or other types of advertising that is, by its nature or design, not clearly separated from the surrounding content; and
- advertiser-created games appearing on third-party websites.
Enhanced disclosures should be prominent, interruptive, and sufficient to identify the marketer and commercial intent and should be used when an ad is aimed at young children (under 12s), highly immersive or significantly integrated into the surrounding editorial content and unlikely to be identified clearly from the context in which it appears. The disclosure should be:
- within or directly next to the marketing communication;
- of significant size and colour to stand out; and
- readily apparent before or immediately at the point of engagement.
ASA rulings suggest that enhanced disclosure should not blend in with the rest of the ad and that using a colour palette and font that matches the style of the rest of the ad does not make the disclosure sufficiently prominent or interruptive enough.
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