The UK’s Committee of Advertising Practice (CAP) has published a new review on the use of children as brand ambassadors and in peer-to-peer marketing – including online where boundaries between what is and is not considered advertising may become blurred.
The review precedes new guidance that CAP says it intends to publish in the first quarter of 2013, which will offer a framework for industry to ensure that regulation of children’s engagement with marketers addresses parental concerns and prevents irresponsible practices.
In particular, the guidance is expected to draw on the existing CAP Code, clarifying that marketing must:
- Be obviously identifiable as marketing activity; and will give examples on how that can be achieved;
- Do nothing that is likely to result in the physical, mental or moral harm of children;
- Not make children feel inferior or unpopular if they do not have a product or do not engage in peer-to-peer marketing and confirm that all rules in CAP’s dedicated Children’s section apply; and
- Be prepared with a sense of social responsibility.
“In the online world, there is considerable potential for the boundary between advertising and non-advertising content to become blurred,” the review said.
It gave examples of online games and invitations to like a brand on Facebook, or to follow a brand on Twitter in order to access additional content or games.
In addition, a company may employ children on a more formal basis with parental consent, as Weetabix did in 2011 when it paid 15 young people to wear branded clothing so it would be seen by their friends.
“The definitions of peer-to-peer activity and brand ambassadors cover a broad range of marketing techniques,” the review said. “However, the level of engagement between the brand and the child tends to vary, which may affect the potential to distort or commercialise friendships.
“Given the breadth and prevalence of techniques by which a child may be incentivised or employed to promote a product or service, any regulatory intervention would need to be based on a clear and detailed understanding of the nature of the practice it addressed and the relative potential harm it sought to prevent.”