An advertisement promoting Pizza Max’s ‘Kids Special’ featured an image of a pizza, chips and a non-carbonated juice drink against a blue background with the Pizza Max logo. The image read:
Pizza & Chips
The Instagram caption read:
“Pizza Max Brings You Our Kids Specials!
Who doesn’t love pizza after all :)
Get hot and piping delicious food right at your doorstep, download our app now or visit: www.pizzamax.ie
#Pizza #PizzaMaz #Delivery #Hot #Favourite #Ireland”
[The Kid’s Meal pizza was a 7” pizza with two toppings](1)
A complaint was received on behalf of the Irish Heart Foundation regarding the advertisement.
The complainants said that the advertisement appeared on the Instagram account of an account holder under the age of 15. The complainants objected to the product being targeted at a person in that age category. They considered that the advertisement was targeting young people through both analytics and calorie count.
The complainants further believed that the use of the words ‘Kids Specials’ was encouraging excessive consumption and encouraging young people to over-consume, depending on their age, to take advantage of a promotion.
The advertisers removed the post in question following receipt of the complaint and they apologised for any inconvenience caused. They said that their sponsored posts targeted Instagram users aged 18-65, and they provided ASAI with statistics from their Instagram account which showed that 80% of their audience was aged 18-65. They said that the kid’s meals were usually ordered by parents via phone or online.
ASAI Executive Research:
The ASAI Executive reviewed the advertisers’ Instagram account at the time of adjudication to establish the number of account followers, which totalled 399.
The ASAI Executive’s research included a 2012 study conducted by Safefood(2) which found that takeaway pizzas were usually high in fat and salt. The results of this study showed that, on average, a 12-inch takeaway pizza often contained more than an adult’s Guideline Daily Allowance (GDA) for energy, saturated fat, salt and protein. The recommendation made by Safefood as a result of these findings was that takeaway pizzas should be considered as an ‘occasional food’ (e.g. once a week or less often).
The ASAI Executive researched Instagram rules for the minimum age permitted for an Instagram account holder. They established that an account holder must be at least 13 years of age(3).
The Complaints Committee considered the details of the complaint and the advertisers’ response. They noted that the advertisers had withdrawn the post on receipt of the complaint.
The Complaints Committee noted that children under 13 were not permitted under Instagram’s terms and conditions to set up an account. The Committee also noted that the advertisers’ audience on their Instagram page was 80% 18+ , that they appeared to have a low number of followers, and that they had targeted the sponsored post to an audience aged 18–65. The Committee therefore did not consider that the advertisement had been targeted at children using analytics.
The Committee further considered whether the advertisement was targeting children through calorie count. They noted there was no nutritional information provided in the advertisement and that, as previously referenced, the advertising was not targeted at children through analytics. They therefore did not believe the advertisement was intended to persuade children to purchase based on the calorie count or type of product offered.
The Complaints Committee considered whether the words “Kid’s Special”, in association with the content of the promoted meal, were condoning excessive consumption or encouraging young people to over-consume, depending on their age, to take advantage of a promotion.
They noted there was no element of time restrictions or other limitations associated with the deal that might be likely to encourage over-consumption specifically to take advantage of the promotion. They considered whether the use of the words “Kid’s Special” was encouraging children to over-consume to avail of the deal because of their age. While accepting that references to ‘kids’ could be of interest to children, in the context of this advertisement, and taking into account the audience it had been targeted at, the Committee did not consider the use of the words “Kids’ Special” to be encouraging children to over-consume to take advantage of a promotion based on their age.
The Committee reviewed the research cited from both the HSE and Safefood and noted that, although takeaway pizzas were found to be typically high in fat and salt, there was no recommendation from either body to eliminate takeaway pizza from one’s diet entirely but rather to consume such foods occasionally and as part of a balanced diet. The Committee did not consider that advertising a kids’ meal comprising of a seven-inch pizza, chips and a juice drink encouraged excessive consumption as there was nothing in the advertisement to suggest the product should be consumed regularly.