Advertising Standards Bureau Review of Operations 2014 | Page 50

The Board considered a number of cases which
involved interactive games on advertiser websites.
In determining whether these marketing
communications were aimed at children, the
Board found that requiring log-in details and/
or a date of birth to play the games was good
practice, however this did not mean the medium
was not directed primarily to children (Kellogg’s
- 0033/14, Unilever - 0089/14 and Lion 0075/14). In determining whether the games
were directed primarily to children the Board
examined the visuals, themes and language of the
advertisements. In a number of cases animated
games with familiar cartoon characters were found
to be directed primarily to children (Kellogg’s 0033/14, Unilever - 0089/14 and Lion - 0075/14).
In 0205/14 (Nestle) the Board found an
advertisement for a chocolate bar which featured
animated characters and bright colours, was not
directed primarily to children, but would appeal
to a more general audience. The Board considered
the themes in the advertisement were slightly
complex and the use of adult characters and voices
meant the advertisement would be attractive to
older audiences.
In contrast an advertisement which featured
bright colours and animation, was found to be
directed primarily at children because of the
simple theme, and the use of only children in the
advertisement (0399/14 Unilever).

Elements of an advertisement
Across 2014 the Board considered that:
•

•

•

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The use of a familiar cartoon character is
not necessarily enough to determine an
advertisement is for an associated product,
if that product is not referenced (Unilever 0089/14 and Lion - 0075/14).
Th
e use of bright colours is also not enough
to indicate that the advertisement is directed
primarily to children as it may also be equally
attractive to adults (Kellogg’s - 0221/14).
The use of animation alone is not enough to
indicate that the advertisement is directed
primarily to children, if the tone and style of
the animation is one that would be equally
attractive to adults (Nestle - 0205/14).

Advertising messaging

Encourage physical activity

Under the RCMI the product advertised must
represent a healthier dietary choice and the
advertising and/or marketing communications
must reference, or be in the context of, a healthy
lifestyle, designed to appeal to the intended
audience through messaging that encourages:

In 0033/14 (Kellogg’s) the Board found that
an interactive game which encouraged children
to pretend to play the drums, was enough to
encourage physical activity:

•

g
ood dietary habits, consistent with
established scientific or government criteria,
and

•

physical activity.

Encourage good dietary habits
In 0033/14 (Kellogg’s), the Board determined
that the omission of any messaging about healthy
dietary behaviour in an online interactive game,
was in breach of the Initiative, even though the
advertised product was one which met the healthy
dietary choices criteria.
In 0089/14 (Unilever) the Board found that
messages encouraging a balanced diet were
enough to encourage good dietary habits:
“The Board acknowledged that there is
considerable difficulty for advertisers on a website
platform to reflect this type of messaging and
considered that in this matter there was sufficient
information around good dietary habits. The
Board noted that the website, incorporates
on-screen messages of “Enjoy … as a treat
within a balanced diet” and “true heroes balance
energy intake with activity” on every page of
the website. The Board noted that the messaging
is written in simplified language that could be
understood by children.”

“The Board noted that the activity itself of
playing the game on the computer was not a
game that required a lot of physical activity per
se. The Board agreed that playing a real set of
drums would most definitely require physical
contribution. The Board considered that the game
itself did not have to include intense physical
activity for the player but that the message that
the game was delivering was a positive message
that would likely encourage children to actively
get involved in playing music or imaginative
games involving music and movement. The
Board considered that the advertisement did
encourage physical activity”.
Similarly, the Board found that wording on
a website which encouraged children to stop
playing online and have an ‘adventure’, did
amount to encouragement of physical activity
(Unilever - 0089/14).
The Board also determined that structured
sport or exercise was not required and the
image of children playing outside can meet
the requirement to encourage physical activity
(Unilever - 0399/14).
The Board also found that, depending on context,
messages that inform a user when they have
been playing an online interactive game for a
certain amount of time was one way to meet this
requirement (Lion - 0075/14).

Similarly in case 0075/14 (Lion) messaging on
the site encouraging healthy eating in simple
language attractive to children was enough to
meet this requirement.
However, the Board found that similar messaging
in a television advertisement was not enough to
encourage healthy eating choices, as the text was
less noticeable when viewed with the movement
and sound on screen (Unilever - 0399/14).

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