Responsible Advertising and Children Programme

This paper represents the views of the marketing communications industry and reflects our common concern that marketing communications in the context of children needs to be both responsible and sensitive to children and families. The Responsible Advertising and Children Programme (RAC) represents advertisers, agencies and media worldwide.

Our Responsibility

Members of the Responsible Advertising and Children Programme work to ensure responsible marketing communications. Marketing communications play an important role in society. They provide consumer information and are also the main driver of brand competition. Competition benefits the consumer. Competition generates innovation, growth, consumer satisfaction, employment and tax revenue for inward investment. Marketing Communications are the principle source of revenues for programming, cultural and sporting events.

Yet the ability to advertise goes hand in hand with particular responsibilities, especially in so far as children are concerned. We recognise that our responsibility is particularly important for marketing communications to children of all ages. This is reflected in the industry’s commitment to a best practice model of effective self-regulation and robust codes of conduct that are participative and accountable.

Marketing communications to children should be seen in the context of parental guidance and must not undermine the authority of parents or other appropriate adult role models. We have a commitment to working with parents and schools to ensure that marketing communications meet society’s high expectations for the protection of children. We know from research that children today are increasingly media literate. However, we recognise too that we have a special responsibility to help our children to gain the skills necessary to interact with the media. We are therefore encouraging and supporting the development of a global programme of media literacy.

Today’s reality

Today’s media environment is very different from just a generation ago. Children use a variety of technologies to access media from many different sources and in many different ways. It is certain that this generation is more media savvy than any of its predecessors.

Children can benefit hugely from the different content available for
them, whether it be for the purposes of education, sport or entertainment. Some commentators have even suggested that the “digital generation” is more stimulated, inspired and responsive as a result of this heightened interaction with the media.
However, while marketing communications may make much of this content free to children, it is essential that they remain responsible and are sensitive to them and their levels of understanding. As such, members of the Responsible Advertising and Children Programme are committed to ensuring that self-regulatory mechanisms and codes for the traditional media (such as television and radio) apply to emerging media (such as the Internet).

Our Commitment

The International Chamber of Commerce (www.iccwbo.org) is the global code owning body, charged with updating marketing communications codes to ensure they reflect changing societal sensitivities. All forms of marketing communications worldwide must conform to the ICC Consolidated Code on Advertising and Marketing, last revised in September 2006. The code includes a specific section, detailing the special care needed when communicating to children. It also includes particular chapters for specific sectors, such as The Framework for Responsible Food and Beverage Marketing Communications. The latter includes a section on food marketing to children.

These codes provide a minimum requirement for marketing communications worldwide. National self-regulatory codes, based on the ICC codes, 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. The ICC and national codes are reviewed regularly to ensure that they remain relevant to local, cultural and consumer concerns and that they promote best practice. Typically, national SROs go further than the ICC codes by developing provisions, which respond to specific national and cultural sensitivities.

These national codes often apply to marketing communications to children. Examples of these can be seen in codes developed by the Children’s Advertising Review Unit (CARU) in the US (www.caru.org) and by Ad Standards Canada (http://www.adstandards.com/en/)

In Europe, the SROs form a network coordinated by the European Advertising Standards Alliance (EASA) (http://www.easa-alliance.org), which works in two ways. First it ensures that the independent self-regulatory bodies and the advertisers, agencies and media all work together to ensure the effective functioning of a system of cross border complaint resolution in the EU single market. Secondly, through EASA, industry has developed and is in the process of implementing best practice in effective advertising self-regulation.

In addition to industry-wide self-regulation, individual companies and industry sectors have introduced a wide range of additional provisions relating to marketing communications directed at children. This provides an additional layer of consumer protection.

Advertising is strictly regulated across Europe. Articles 10-16 of the Television Without Frontiers Directive set out these rules for all Member States of the European Union. The Directive is currently being revised to cover all Audio-visual media services.

Article 16 is dedicated to advertising to minors:
Article 16
Television advertising shall not cause moral or physical detriment to minors, and shall therefore comply with the following criteria for their protection:

It is crucial that children understand the media environment. The Oslo Challenge, issued by UNICEF in 1999 states that "the child/media relationship is an entry point into the wide and multifaceted world of children and their rights - to education, freedom of expression, play, identity, health, dignity and self-respect, protection - and that in every aspect of child rights, in every element of the life of a child, the relationship between children and the media plays a role."
The World Health Organisation also notes that the “acquisition of media literacy, starting in primary school, [is] important to promote healthier diets, and to counter food fads and misleading dietary advice.”

We believe that educating children to understand the purpose and context of marketing communications helps them to develop the skills to critically interpret commercial communications in the context of their daily lives. This is crucial in preparing them for interaction with the reality of a media-filled world.

Media Smart (www.mediasmart.org.uk) was launched in 2002 in the UK. It is paid for by advertisers, while agencies provide the creative and the media give the airtime. All in-school materials are developed by independent media literacy experts. The Responsible Advertising and Children Programme has helped drive the successful launch of similar such initiatives in, Belgium, Germany, the Netherlands, Finland and Sweden.

When talking about the digital media citizens of the future, Tim Suter of Ofcom, the UK independent broadcast regulator, said at to a meeting of stakeholders in January 2007:

“Media Smart so obviously, so patently gets it. It understands that that’s the challenge of the future, it appeals to children clearly, it appeals to teachers equally clearly. It appeals to industry, people in this room are a testament to that and it appeals to policy makers, ditto.”

The programme has also been endorsed by the European Commission, the Dutch and UK governments and was described on its launch by Tessa Jowell, UK Secretary of State for Culture, Media and Sport as “enlightened self-interest”.

Marketing communications revenue makes a significant contribution to children's programming content. Put simply, advertising finances children's programming on free-to-air television. A study conducted by the Association of Television and Radio Sales Houses (egta) among 15 sales houses, representing 12 countries within the European Union, reveals that 94% of the net revenues coming from advertising aimed at children are reinvested in children's programmes (241 millions Euros). In the digital economy, there is no alternative method to ensure investment in original children's programming and in the acquisition of programme rights.

Not only does marketing communications help to guarantee quality children’s programming, it also aids competition in the wider economy, creates jobs and enhances consumer’s choices of goods and services. In return, advertisers are active and enthusiastic supporters of strong self-regulation ensuring that we meet the expectations of parents, regulators, and society at large.

Education and self-regulation deliver effective and responsible marketing communications. As members of the RAC programme we are committed to responsible marketing communications for children of all ages. Marketing communications are a feature of the world in which our children live. We look forward to working with all key stakeholders to ensure the continued strengthening and development of the self regulatory framework so that it continues to address the legitimate concerns of parents, as well as help develop a global programme of media literacy.