CAP continues to protect children and young people by issuing new guidance on non-broadcast ad placement of age-restricted products. The guidance helps marketers of age-sensitive products and services adhere to the CAP rules on age-restricted marketing communications i.e. such products and services must not be placed:
- in or around media that is obviously directed at children (under 16s) or children and young people (under 18s), for example, teen interest magazines or games websites for young children.
- in or around other media where the protected age category makes up more than 25% of the audience.
Marketers of certain age-restricted products, will already be familiar with such rules. For example Alcohol and gambling have long been subject to such restrictions, electronic cigarettes have been recently restricted, and from July 2017, ads for food and soft drink products high in fat, salt and sugar will also be subject to similar restrictions.
Marketers will need to ensure that their ads are carefully placed and be aware of their target audiences, by ideally holding robust audience measurement data, so that they can demonstrate that they are aware of who will see their ads and they can legitimately be targeted with age-restricted products. Where such data is created on the basis of marketing lists or similar, steps should be taken to avoid direct communications at age categories which have such restrictions in place.
General communications to the population for example outdoor media or circulars, are unlikely to fall foul of the 25% threshold. However this may not always be the case, for example if the communications are made near to schools, the audience may be different and much more likely to exceed the 25% threshold.
CAP emphasises that marketers remain responsible for compliance with the Code, even when the failure in compliance is due to the failure of an affiliate or intermediary.
CAP will also issue further guidance on media placement in the forthcoming months.
The author wishes to acknowledge the contributions of trainee Robert Grannells to this article.