We focus a lot on this blog on claim substantiation.  That is largely what we do, and largely where our readers focus.  But a review of CARU’s decisions in the past month serve as a good reminder that when directing ads to kids under 12, there is more than substantiation at issue.  Advertisers have a higher burden of presenting socially appropriate and safe situations.  And a higher burden in looking at the ad through the impressionable lens of the intended young audience and providing clear disclosures.

What is included with your purchase?  Lego ran an ad featuring two sets from its City collection — a helicopter and forest police station.  It showed the sets as sold and included at the end that the sets were sold separately, depicting both packaging.  The sets were shown assembled with additional Lego dirt and grass and trees to set the forest scene not included with the sets.  CARU was concerned kids would be confused over what was included with purchase.  Lego said they have never gotten complaints about such confusion and have tested focus groups of kids who say they like to see the playsets shown with more context to set the scene.  The camera in the ads zooms in and only focuses on the actual product being advertised and the end of the commercial shows the products without the forest scene pieces.  CARU still recommended Lego make clearer that the scene setting items are not included with the purchase.

Are the kids safe?  A “don’t try this at home” or disclaimer that the ad features professional stunt artists may not cut it in the children directed advertising context.  In a case involving the Splash Blaster outdoor water toy, CARU asked the advertiser Big Time Toys to modify the advertising for the product to better show adult supervision.  Kids were shown playing with the water balls in or near a pool but no adults were shown.  The audio disclosure to “Always Swim with Parents Present” was not deemed sufficient and the advertiser agreed to modify its ads to show more meaningful adult supervision.

Are foods shown to encourage healthy eating choices?  CARU’s guidelines ask that in ads for meals reasonable serving portions of balanced meals showing at least 3 of the 5 major food groups and in child directed ads.  A recent Kraft Lunchables ad showed a child in a school office eating the PB&J from the lunch but did not depict the oranges that also came with the meal.  The ad showed other children in a school lunchroom scene eating lunches with milk or juice so tried to communicate the balanced meal message.  CARU said the child eating the Lunchables should have been shown with a balanced meal and later references to other children would not suffice.  In this case Kraft sent the storyboards for the campaign for review and CARU approved them without flagging this issue.  CARU cautioned that it “does not issue blanket approval for an entire campaign after reviewing one phase of the advertising campaign.

Is it clear to kids your online game is an ad? CARU recently suggested that in future games directed to kids on its website that had a commercial message integrated into the content that IHOP clearly label it as an advertisement.  The Save the Truffula Valley game directed players to eliminate axes in the forest to save the valley and ultimately treat the player to a delicious Lorax breakfast at IHOP.  While IHOP assured CARU the game was no longer running, it asserted it was not advertising and that its website was not directed to kids.  CARU found while the website as a whole was not specifically intended for children that kids were directed to the website by commercials airing during children’s programming.  And the featuring of IHOP breakfast items was a commercial message.

So it takes a village to raise children and this includes national advertisers.