Why the Responsible Advertising and Children Programme?

RAC helps its members to anticipate and understand societal and parental perceptions of and aspirations for responsible marketing communications and children. Trust is critical to our industry, both to how we are perceived by society and how we communicate effectively with our consumer. RAC’s role in helping build trust is to provide global leadership by championing good practices in marketing communications to children. This exercise is shaped by a continued dialogue and engagement with policy-makers, society and consumers.

Members of the Responsible Advertising to Children Programme (advertisers, agencies and media worldwide) work to ensure that marketing is sensitive to the needs and concerns of children and families. We work toward this objective by:

1. Reaching out to parents and stakeholders to understand societal expectations: Marketers are great communicators and are often innovative and creative. By listening to parents and families, marketers can use their skills to help parents convey messages that help children adopt good habits. Parents often say they need support in promoting right versus wrong, healthy nutrition, the importance of sleep and exercise and so on. We work with parents, schools and child experts to identify opportunities to use marketing to help convey positive educational messages.

2. Reaching in to marketers to sensitise them to societal expectations: RAC members recognise that marketers must be conscientious about any form of communication that is likely to appeal to children. We seek to build trust in marketing communications by ensuring that we apply robust standards through effective self-regulatory systems.

3. Media literacy: We believe that young children need to develop skills to engage with today’s media-filled world. This is why we are committed to promoting media literacy through independently formulated media literacy programmes, such as Media Smart (www.mediasmart.org.uk).

What does ‘responsible advertising to children’ mean?

Marketing communications to children must meet the standards established by law and by international and national codes of conduct.

In addition to full compliance with legislation, we are committed to the Consolidated Code on Advertising and Marketing of the International Chamber of Commerce (ICC). This code includes a specific section that details the special care needed when communicating with children. The ICC is also the repository of the Framework for Responsible Food and Beverage Marketing Communications, which sets out the minimum requirements for rules on food and beverage marketing communications directed at children applicable through transposition into national codes of conduct. Additionally, RAC helps establish self-regulatory infrastructures in order to ensure that codes are monitored, policed and enforced according to best practice standards.

But responsibility goes beyond compliance. RAC helps marketers to understand changing societal sensitivities so that marketers can better reflect these in their marketing communications. For example, in response to concerns over childhood obesity, RAC helped launch the EU Pledge Programme (www.eu-pledge.eu) in order for companies to help parents promote healthier diets and lifestyles to their children.

What do these codes say in practice?

Key elements of the ICC code in relation to communications to children include:

  • No undermining the authority, responsibility, judgment or tastes of parents, having regard to relevant social and cultural values.
  • No direct appeal to children and young people to persuade parents or other adults to buy advertised products for them.
  • No inferring that possession or use of the promoted product will give a child or young person physical, psychological or social advantage over other children.
  • No undermining positive social behaviour, lifestyles and attitudes.
Do you follow the same codes of conduct for marketing communications everywhere?

Our commitment to responsible marketing communications is local, regional and global. The ICC code provides a minimum requirement for marketing communications worldwide, alongside national and regional laws.

We are also committed to more detailed national self-regulatory codes that are established, policed and enforced by local Self-Regulatory Organisations (SROs) and industry in over 100 countries worldwide and apply to a range of media including digital marketing communications. Typically, national codes go further than the ICC codes by developing provisions that reflect local sensitivities. National codes are developed on the basis of multi-stakeholder consultations to ensure that the codes respond to societal interests. Examples of national specifications can be found in the codes developed by the Children’s Advertising Review Unit (CARU) in the United States (www.caru.org) and by Ad Standards Canada (http://www.adstandards.com/en/). National codes in Europe can be accessed via the European Advertising Standards Alliance (EASA) (http://www.easa-alliance.org), which coordinates the network of European SROs.

Do your commitments to responsible advertising to children extend to all forms of media?
We are committed to the Consolidated ICC code which indeed applies to marketing communications in all media. An increasing number of national self-regulatory systems have been upgraded in the last few years to ensure that self-regulation keeps up with technological developments and is able to enforce high standards across all media. In Europe, this is being facilitated by Best Practice Guidance developed by the European Advertising standards Alliance (EASA) and currently being implemented across the region.
How are the codes of conduct monitored and enforced?
The codes are enforced by national self-regulatory organisations (SROs). Complaints are handled by adjudication committees within national SROs, comprising a wide variety of stakeholders to ensure impartial decisions. Industry also commissions regular independent monitoring of the codes of conduct to verify that the provisions on advertising to children are being applied effectively. For example in Europe industry commissions independent monitoring of the implementation of national rules based on the ICC Framework for Responsible Food and Beverage Marketing Communications.
Can advertising self-regulation protect children?

Independent studies acknowledge that advertising self-regulation ensures a high level of protection for consumers, especially children. Studies undertaken by the European Commission found that advertising self-regulation “seem[s] to be especially successful with respect to the application of rules on advertising and the protection of minors”.

European Commission, “Study on co-regulatory measures in the media sector,” available at: http://ec.europa.eu/avpolicy/docs/library/studies/eac/03_04_annex1.pdf

Is self-regulation a substitute for legislation?
Self-regulation cannot operate in a vacuum. Self-regulation is most effective when it functions within a national or regional legal framework which sets industry-wide parameters for marketers (e.g. rules to prevent any form of misleading advertising). Legislation and self-regulation can work hand-in-hand if the legal framework recognises the role of self-regulatory systems in implementing the objectives of the law and encourages operators to implement specific provisions through codes of practice that respond to societal concerns.
Some groups have argued that it would be better to simply ban advertising to children. Why do you disagree?

It is important to be clear about what the objective of a ban on advertising to children would be and whether a ban is likely to achieve that objective. Some view advertising bans as policy tools to thwart rising obesity rates. There is strong evidence, however, from the U.S., Canada, Australia, UK and the rest of Europe that obesity rates have been rising despite a decline in food and beverage advertising volume and a reduction in children’s exposure to food and drink ads. We believe that harnessing the skills of the advertising industry to promote good dietary habits and healthy lifestyles can contribute more productively to public policy objectives than a ban.

Others support an advertising ban to children on ethical grounds, based on the belief that commercial activities are pernicious to children’s wellbeing. However, the best available scientific evidence on children and the commercial world concludes that children’s fundamental values have remained constant over the last 15 years, despite the importance placed on consumerism in today’s society. There are also indications of increased media literacy and resistance to advertising among children. In Europe, a recent Eurobarometer survey confirms that the physical and mental health of children in the EU is improving, not deteriorating.

We believe the commercial world, in which advertising and marketing play an essential role, makes an important positive contribution to children’s wellbeing. The media, arts and culture, which are largely funded by advertising, are important enablers of children’s wellbeing.

We nonetheless recognise the need for safeguards to prevent children from being the target of misleading, exploitative or aggressive marketing practices. We therefore support proportionate regulatory frameworks, complemented by effective self-regulation at national, sectoral and company levels.

What does responsible advertising to children mean with regard to food advertising?

Our vision of responsible food and beverage marketing communications to children is that (1 – “Nature of advertising”) advertising content must meet high ethical standards and (2 – “Balance of advertising”) companies should ensure that they promote healthier options for children.

Under the first principle, marketing communications must meet the ethical standards set in law and in international and national codes of conduct, e.g. the ICC Framework for Responsible Food and Beverage Marketing Communications. Key elements of this code include:

  • “Accurate, non-misleading representation of food and beverage products, including nutrition or health benefits”.
  • “No representation of food products as substitutes for meals if they are not intended as such”.
  • “No encouragement or condoning of excess consumption and appropriate portion sizes”.

The second plank of our vision means that companies should limit marketing communications directed at children to products that meet certain nutritional requirements, based on accepted national and scientific guidelines. Our two-pronged approach to responsible food and beverage marketing communications to children ensures that such communications are truthful, non-misleading and promote moderate consumption, a balanced diet and healthy lifestyles.

What is industry doing to protect children and promote children’s health?

Industry and Self-Regulatory Organisations (SROs) have put in place codes of conduct for responsible food and beverage marketing in most markets around the globe. The provisions of the ICC Framework for Responsible Food and Beverage Marketing Communications have been transposed into national codes of practice in a large number of countries worldwide (including Argentina, Australia, Brazil, Canada, Chile, almost all EU Member States, India, Mexico, New Zealand, South Africa, United States). These codes are designed to ensure that marketing communications are legal, decent, honest and truthful and respectful of the special sensitivities of children.

Voluntary commitments to address food advertising to children that go beyond most national laws and the ICC codes have been launched globally, regionally and nationally. Most international food and beverage companies have developed global policies on food and beverage marketing communications to children. Additional initiatives, “Pledge Programmes”, to change food marketing communications to children have been unveiled in the United States, Canada, the EU, Thailand and Australia. All of these initiatives have in common a commitment to limit child-oriented marketing communications to products that meet a specific nutritional criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines. Companies participating in the initiatives are committed to independent, transparent and participative compliance monitoring, which will be carried out annually.

What are you doing to promote media literacy?

RAC members are leading supporters of independently drawn up media literacy education programmes. This, in the belief that enabling children to develop a critical understanding of the media and commercial communications is essential in today’s media-filled world.

The Media Smart (www.mediasmart.org.uk) was launched in 2002 in the UK and provides children with media literacy skills at an early age. It is paid for by advertisers and was developed by advertisers, media agencies and broadcasters. Media Smart has already been taught to over a million children in the UK, and is now present in 27,000 primary schools across Europe (Belgium, Finland, Germany, Hungary, Netherlands, Portugal, Sweden and the UK). UK and EU regulators and child experts have recognised the positive contribution of Media Smart to education and media literacy.

Media Smart recently launched a new set of independently drawn up teaching materials (Be Adwise 2), which aim to build up children’s literacy skills with regard to the digital media, which are of growing importance in their lives. The programme has received extensive government and stakeholder support and is being requested by a large number of schools in the UK.