CARU – Children’s Advertising Review Unit is a self-regulatory program under the National Advertising Review Council (NARC). CARU sets high standards in order that the advertising targeted towards children is responsible and fair with regards to the vulnerability that children have due to immaturity and susceptibility of influence. CARU’s role is monitoring and they are a very powerful division of the CBBB, the Council of Better Business Bureaus.
Here is a summary of the guidelines. For the original policy CLICK HERE.
The content will be analyzed by (a) whether the content of the media in which the advertisement appears is intended for children under 12 (b) when and where concerning the time of day during the programming the advertising is placed and if it falls under The Children’s Television Act (c) the time of the placement of the advertisement due to the subject matter.
The consideration of collection from online data.
National Advertising – means any paid commercial message in any medium including labeling with the purpose of inducing a sale or commercial transaction disseminated nationally or substantially nationally.
Advertiser – Any person or entity that engages in the above for broadcast or online transactions.
- Advertising should be fair and take into account the nature of children.
- Advertising should be neither deceptive nor unfair.
- Advertisers should have adequate substantiation for objective advertising claims.
- Advertising should not stimulate unreasonable expectations about the product to children.
- Advertising should avoid stereotyping and prejudice.
- Advertising should be educational and honest.
- Advertising should contribute to the parent-child relationship.
- The advertisement should not mislead children about what is included in the initial purchase.
- Advertisements should be placed in the same way that the product performs with children’s use.
- Advertising that compares products should be based on real product attributes understandable to the child.
- The portion or amount of the product featured should not be excessive concerning serving size or portion size.
- Food advertisements should encourage reasonable healthy use of the product or encourage a healthy lifestyle.
- Advertisements for food products should clearly depict or describe the appropriate role of the product with the scope of the eating occasion depicted.
- If an advertisement is at mealtime the food depicted should be incorporated within a nutritionally balanced meal.
- Snack food should be depicted as a “snack.”
- All disclaimers and disclosures should be understandable to children.
- Disclosures should be conspicuous and obvious to children on broadcast and on online.
- Advertisers should use audio disclosures for children.
- Circumstances for Disclosures
- Unassembled products should depict that they come unassembled and have to be put together.
- If any item is not included that is paramount to functioning, it must be disclosed (like batteries).
- If any phone numbers are involved (especially tool-free numbers) it ust be clearly stated in both audio and video disclosures that the child must get the adult’s permission. This is for all advertising.
- Advertisers that create or sponsor an area must clearly identify themselves by the sponsoring company and brand name. This should be done using “Sponsored by….”
- If any DVDs ir CDs include advertising then it must be clearly disclosed on the packaging.
- Advertisers must realize the significance of celebrity endorsement and be careful not to create false impression.
- All personal endorsement should reflect the true real feeling of the endorser.
- An endorser who is represented either directly or indirectly, who is presented as an expert, must clearly be an expert.
- Advertising should not be blurred with content and should clearly be depicted as advertisement.
- Program personalities, live or animated, should not be used to advertise products, premiums or adjacent to a television program primarily directed to children under 12 years of age in which the same personality or character appears.
- Products derived from or associated with a television program primarily directed to children less than 12 years of age should not be advertised during or adjacent to that program.
- In media other than television, a character or personality associated with the editorial, content of the media should not be used to sell products, premiums or service in close proximity to the program/editorial contend, unless the advertiser makes it clear, in a manner that will be easily understood by the intended audience that it is an advertisement.
- Requiring the use of a credit card in connection with a transaction is a reasonable effort to provide the person responsible for payment with control over the transaction. This is consistent with COPPA regulations 16 CFR § 312.5
Premiums and Contests
- Advertisers should realize that contests and premiums and sweepstakes have the potential to entice and enhance the appeal of the product.
- Advertisers should take special care promoting contests with age appropriate expatiations.
- The premium message must be secondary to the product advertisement.
- The conditions of the paramecium must be clearly stated.
- Advertising should not mislead children into thinking that they are joining a club when they are making a purchase or receiving a premium.
- To use the word “club” the advertiser must,
- Interactivity – The child must have some act of demonstrating intent to join the club and receive something in return.
- Continuity – There must be an ongoing relationship. Like regular newsletters or activities.
- Exclusivity – The activities or benefits derived from membership in the club should be exclusive to its members.
Sweepstakes and Contests
- Advertisers should realize that children have unrealistic expectations of winning.
- The prizes should be clearly depicted.
- The free means of entry must be clearly disclosed.
- The likelihood of winning should be disclosed – only one winner from our many entries!
- All prizes should be appropriate for the audience.
- Data collection should be kept to a minimum and follow th Children’s Online Privacy Protection Act (COPPA).
- Advertisers who sell online should clearly depict to children that they are being targeted for a sale.
- If an advertiser offers the opportunity to purchase any product or service through a click or a button, the instructions must clearly state that the child mut have the parent’s permission.
- Online advertisers must take reasonable efforts in light of all technology available to provide the person responsible for paying must have control over the transaction rather than the child.
- If no reasonable means is provided to avoid the transaction the advertiser should enable the person responsible for the payment the ability to cancel and receive full credit on all charges.
- Advertising should not encourage children to ask parents to buy products.
- Advertising should not suggest that the person who buys or the parent who buys is better or smarter than the rest.
- Advertisers should avoid the word “now” – like buy it now!
- Advertisers should not convey peer pressure.
- Advertisers should not imply that the purchase or use of the product will create power, prestige or other special qualities.
- Advertisers should not use the words “only”, “just” or “bargain.”
Inappropriate or Unsafe Advertising
- The use of products that pose safety risks should be excluded. Where a warning is needed, one should be given.
- Advertisements for children’s products should show their use with children of the appropriate age.
- Children should not be displayed in unsafe situations or without safety equipment.
- Advertisers should be aware that household products can be dangerous and demonstrate proper use of products.
- Violence and sexuality should be excluded.
- Unduly frightening children or provoking anxiety should be avoided.
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