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ASAI Code 7th Edition: 2.4(c), 8.16(a), 8.16(b), 8.18
Advertising for Kellogg’s Coco Pops on Facebook and YouTube featured children sitting at a table eating a bowl of Coco Pops.
Twelve scenes mostly showed children talking individually behind a long table in a studio-type set. Some scenes partly showed views of a jug of milk, glasses of water, and a bowl of fruit. Adults also featured at various stages.
The majority of colours contained within the advertisement were vivid with a bright yellow background. The music playing in the background was upbeat and childlike.
One scene featured a child dancing while another featured a child doing a cartwheel.
In both media the following question was posed on screen to the children
“How does Coco Pops make you feel?
The answers to the question were the following:
Child No. 1 “Happy”
Child No. 2 “Like I'm in heaven”
Child No. 3 “They’re amazing;
Child No. 4 “I love the taste”
Child No. 5 “Delicious”
Child No. 6 “Excellent”
Child No. 7 “Delicious”
Child No. 4 (again) “I wish they had chocolate in everything”
Child No. 2 (again) “Scrumdiddlyumptious”
The on-screen text read:
“*30% less sugar on average than other chocolate flavoured toasted rice cereal. IRl. UK. 2018. For verification see www.cocopops.com
*Now with 30% less sugar.
In both media the advertisement ended with the Coco Pops signature tune:
“I’d rather have a bowl of Coco Pops.”
The Irish Heart Foundation (IHF) expressed concerns regarding the content of the advertising.
They considered the advertisement to be in breach of Section 8.16b of the Code which stated that marketing communications should not mislead children as to the potential benefits from consumption of a product either physically, socially or psychologically. In this regard they considered that the advertisement had clearly portrayed children stating that they were in heaven and very happy when eating the chocolate cereal.
Two consumer complainants expressed similar concerns to those raised by the IHF and considered it inappropriate (even if the cereal contained 30% less sugar) for children to see a young girl stating in an advertisement that she liked chocolate in everything. They considered a statement such as this would make the product appealing to children and that the advertisement had been targeting children.
One complaint stated that children did not need their thoughts to be manipulated and described the impact on her children towards the product having seen the advertisement. She stated that young children are psychologically underdeveloped and she and another complainant stated that they are also vulnerable.
Another complainant stated that it was misleading to have children advertising the product category to other children. She stated that peer endorsement was very powerful and should not be used for the product category concerned.
The Irish Heart Foundation also considered the advertisement to be in breach of Section 8.18 of the Code which states that communications should not condone or encourage poor nutritional habits or an unhealthy lifestyle in children. In this regard, they considered it to be inappropriate to feature a young girl exclaiming that she would love to have chocolate in everything.
One complainant stated that remarks by the children made the product appealing to children.
The advertisers said that they took complaints of this nature very seriously and that they had robust measures in place to ensure that their advertising materials complied with the relevant advertising codes and regulations.
The advertisers said that the specific advertisement had been based on the idea that parents wanted to know about any changes in breakfast options available to their children. In this particular case, as advertisers, they had wanted to raise awareness to parents, and to parents only, regarding the fact that they had reduced the sugar content in Coco Pops breakfast cereal without affecting the flavour. This meant that Coco Pops were still tasty and could easily be enjoyed with their children as part of a healthy and balanced diet.
They said their on-screen messaging had drawn attention to the fact that the product was “Just as delicious” even if it had “30% less sugar” and their disclaimer had outlined the fact that the cereal had “30% less sugar on average than any other chocolate flavour toasted rice cereals.
The advertisers reiterated that their advertising had not been addressed to children and had been executed in a humoristic style. They said the expressions used by the children had been intended as spontaneous jokes of how they felt when eating the product.
They considered the expression in relation to wishing there was ‘chocolate in everything’ or to feel like ‘being in heaven’ when eating it, to be clear jokes that both parents and children would comprehend as being an expression of a clear inclination for a specific taste. They said the expressions had been used to indicate that the children still liked the cereal a lot even though it contained less sugar.
The advertisers confirmed that they never targeted children via social media. Their intended audience for this particular advertisement had been “parents, mainly mums”.
The advertisers pointed out that they had used other methods of communicating the importance of a varied diet and active lifestyle. This included featuring a breakfast scene which had included a balanced breakfast of cereal fruit and milk. They said they were in fact a signatory of the EU pledge (1) and fully appreciated the sensitivity surrounding high fat sugar and salt (HFSS) products and advertising to children alongside the importance of communicating the benefits of a varied diet and active lifestyle. They said they were exceptionally conscious of their responsibility to consumers.
In conclusion the advertisers said that they had not been denigrating an unhealthy lifestyle or encouraging an unhealthy lifestyle or eating habits
The advertisers said that, having reviewed the complaints and allegations made which stated that they had breached the Code and, while they believed that the advertisement was not a violation of such Code, they wanted to avoid any potential misinterpretation. It was for that reason that they decided not to use it again and to proactively withdraw it.
The Executive conducted research on Facebook and YouTube in relation to age gating and audience targeting. In relation to Facebook the following information was provided to those who wished to advertise on this platform:
“About Age-Based Targeting (2)
The minimum age on Facebook is 13, so all ads will be targeted only to people at least 13 years of age. Advertisers promoting products with age restrictions in different locations should adjust this setting before submitting their ads”.
Age-restricted videos are not visible to users who are logged out, are under 18 years of age, or have Restricted Mode enabled”.
In further comments the advertisers said that they used age gating controls and filters offered by Facebook and YouTube. For Facebook they said they had set all of their pages to 18+. This meant that no user under 18 should be able to access the content of their page or receive any post promoted from their page. They said that users on Facebook had to be logged in to access it and to log in they had to provide their age.
For YouTube the advertisers said that they had also set an 18+ target for their advertising.
This meant that anyone logged in and under 18 should not have access to the content. The advertising would not have been available to anyone who was not logged in or who had “restricted mode” enabled. They said that they did not apply such filters to their own site on YouTube and in theory the advertisement would be available to view regardless of age. In reality, however, it was very likely a viewer could only receive an advertisement that would take them to the Kellogg’s page if they were using a device that considered them to be an adult, as they only targeted adults with their advertising on social media. They concluded, therefore, that the main likely audience the advertisement was available to consisted of adults and not children.
The advertisers said that it was quite common for children to be used in advertising for food products to address parents and not necessarily other children. They said the mere participation of children did not necessarily mean that the advertising was being targeted at them.
(1) https://www.eu-pledge.eu/ - “The EU Pledge is a voluntary initiative by leading food and beverage companies to change the way they advertise to children. This is a response from industry leaders to calls made by the EU institutions for the food industry to use commercial communications to support parents in making the right diet and lifestyle choices for their children.”
The Complaints Committee considered the details of the complaints and the advertisers’ response.
The Committee noted that the intended audience for the advertising had been adults. As a result of the use of age filters, the Committee did not consider that the advertising was addressed to children. In the circumstances they did not consider the advertisement to be in breach of the Code.
Complaint 1 Not Upheld.
The Complaints Committee noted that while the advertisement showed some product consumption, and in a studio type setting, it had not featured any meal or snack times which might have been indicative of any particular lifestyle. Accordingly, they did not consider that the advertisement could be seen as promoting an unhealthy lifestyle in children. Some scenes included partial views of fruit, milk and water. While the advertisement primarily focused on how the children felt on consuming the product, the Committee did not consider that the scenes depicted or inferred that content related to nutritional habits. Accordingly, they did not consider the advertising to be in breach of Section 8.18 of the Code.
Complaint 2 Not Upheld.