UK Advertising CAP Code Reform: Proposal to Prohibit Television Advertising Directed to Children Less Than Seven Years of Age

This is an edited version of the final paper I wrote for the subject ‘Advertising, the Media and Marketing Communications’ at the University of Nottingham, England. It outlines my proposal for a reform of the UK’s advertising code of conduct to protect children from unnecessary exposure to advertisements. 

Introduction

This essay will explore the psychological and ethical implications of advertising on children and proposes that the UK advertising codes (CAP) should be reformed to prohibit broadcast television advertising directed to children less than seven years of age. The premise of this reform is centred on the vast body of psychological research and child advertising literature that asserts children, under the age of seven, have not yet developed the cognitive skills or defences to understand the persuasive selling intent of visual, television commercials. As a result, children are seen to constitute a vulnerable societal group that requires additional regulatory guidelines.

This essay will present a theoretical, balanced analysis of the recommended reform by drawing upon psychological and sociological evidence of the cognitive development of children less than seven years of age. Instead of proposing to ban all forms of advertising directed towards children, this essay will specifically focus on broadcast television commercials for three main reasons. Firstly, the visual and engaging stimuli of television mean that children are more susceptible to the persuasive intent of advertisements. Secondly, despite the growing presence of other forms of media, television still has the highest level of commercial exposure to children (Bailey, 2011: 54). Thirdly, prohibiting television commercials, rather than banning all advertising to children, is seen as a balanced compromise that serves the interest of both parties – that is, businesses would still be able to market their products through non-broadcast communication channels and children would be able to develop their cognitive processing abilities independent of the persuasive messages conveyed by television advertisements. Finally, this essay will acknowledge some of the criticisms and limitations of the presented analysis. Overall, the main objective of this essay is to propose a reform in the field of broadcast advertising to children to better reflect the spirit of the Code – that is, to uphold a “responsibility to consumers and society as a whole” (CAP, 2010: 12).

The argument

The central question that is at the forefront of this essay’s argument is: if children have not yet developed the cognitive ability to understand the persuasive selling intent of television commercials, is it morally and ethically fair to advertise to them? Over the last five decades, there has been extensive recognition that “children constitute a special advertising audience, with distinct needs and vulnerabilities” (Armstrong and Brucks, 1988: 99). Beginning in the early 1970s, research emerged that suggested young children do not possess the necessary cognitive abilities to understand the persuasive intent of advertising, but rather, viewed television advertisements as informative, truthful and entertaining (Blatt et al., 1972; Ward et al., 1972). As a result, controversy over the issue peaked in 1978 when the Federal Trade Commission (FTC), an independent agency body of the United States of America, proposed to ban television advertising to young children under the age of eight. Due to strong objections from within the marketing industry and external businesses, the proposal was subsequently defeated. However, concerns pertaining to the negative effects of advertising on children still remain. In June 2011, the Bailey Review – a British parliamentary review on the commercialisation and sexualisation of children – presented a series of recommendations to the ASA to ensure that the “regulation of advertising reflects more closely parents’ and children’s views” (Bailey, 2011: 52). Furthermore, tighter broadcast regulations have been imposed in countries worldwide – in particular, Sweden and Quebec have banned television advertising to children less than 12 and 13 years of age respectively.

Most parties recognise that children represent a vulnerable societal group that should be protected. However, disagreement lies with the “specific issues and solutions” and the extent to which regulatory protectionist measures are necessary (Armstrong and Brucks, 1988: 99). The BCAP Code acknowledges that broadcasters must take “special care” when scheduling advertisements that “might be unsuitable for children” (2010: 126). Even though the current regulations do acknowledge that children require additional protection, they inherently overlook the fact that children – specifically those under the age of seven – do not have the ability to understand advertising’s persuasive intent or have sufficient cognitive defences in place. According to Brucks et al. (1988), cognitive defences are defined as a child’s understanding of the “selling intent of commercials and an associated distrust of ads” (1988: 471). Without cognitive defences, children less than seven years old are unable to assess the claims made by advertisements and are more likely to accept them as informative and truthful messages, rather than being persuasive and biased. The following psychological and sociological theories will seek to provide evidence and support to these claims.

Theories and justification

From a moral perspective, broadcast advertising on children is deemed to be inherently “unfair and deceptive” as young children do not possess the cognitive abilities to “understand the selling purpose of, or otherwise comprehend or evaluate, the advertising they see” (FTC, 1978: 27). The premise of this argument is founded upon psychological developmental models that characterise age related shifts in cognitive abilities. One of the most well-known and developed models is Jean Piaget’s theory of child cognitive development, which proposes four main stages: sensorimotor (birth to two years), preoperational (two to seven years), concrete operational (seven to eleven years) and formal operational (eleven through to adulthood) (Ginsburg and Opper, 1988). In the sensorimotor and preoperational stages, children are ‘perceptually bound’ and can only focus on a single dimension or stimulus in their environment. For example, when viewing an advertisement on television, children in these two stages are only able to distinguish commercials on the basis of dominant perceptual features (e.g. advertisements are shorter) instead of their motive (e.g. advertisements are intended to sell products) (John, 1999: 185). Children in the concrete operational stage – who are seven years of age or older – begin to develop awareness and scepticism of the underlying objectives of commercials, which allows them to form a basic level of cognitive defence. Piaget’s theory is useful in describing age related patterns of development, but one of its main restrictions is that it fails to provide detailed insight into how or the extent to which children process information they are exposed to.

To overcome some of the limitations of Piaget’s theory, Robertson and Rossiter present the information processing concept of attribution theory. Attribution theory concerns the perception and processes by which individuals interpret and sort incoming information and events in their subjective environment (Heider, 1958). In other words, children who have the ability to discern persuasive intent using attribution theory are less likely to be influenced by advertising they view. Robertson and Rossiter assert that the development of recognition in persuasive intent attributions can “act as a cognitive defence to persuasion” (1974: 19). However, even though children may recognise a commercial, this may not automatically translate into an understanding of their selling intent. Butter et al. (1981) found that, by the age of five, almost all children have acquired the ability to discern commercial slots from regular television programmes, but 90 per cent of five year olds could not explain the differing purposes of the two – that is, the purpose of providing a form of entertainment or inviting the viewer to purchase a product. In line with Piaget’s theory, the understanding of advertising’s intent eventually emerges when children are seven to eight years old (Robertson and Rossiter, 1974; Ward et al., 1972). Armed with knowledge about commercial’s persuasive intent and the degree of truthfulness in them, children above the age of seven are viewed as having the ability to respond to television advertising in an increasingly informed and mature manner.

Other than psychological theories, we can also draw upon sociological theories to aid our understanding of the complexities of children’s development. Selman (1980) provides a description of children’s ability to understand differing social perspectives. In the initial egocentric stage, children under the age of six are unaware of any other perspective besides their own – that is, they are incapable of understanding that others may have differing motives or opinions. Selman (1980) concludes that the ability to distinguish persuasive intent in advertisements firstly requires one to view commercials from the advertiser’s perspective. However, this ability does not surface until children reach the self-reflective stage at eight to ten years old.

Contemporary social issues, such as the increasing trend and degree of materialism in children, are also of concern. Television advertising fuels a greater understanding of the social significance of certain goods and, as demonstrated by Goldberg et al. (2003), materialistic and consumerist values are inherently crystallised by the time children reach fifth or sixth grade. Over the longer term, cumulative exposure to television advertisements will shape the development of a child’s values and attitudes. As a result, television advertising is seen to perpetuate ideals of social inclusion through material possessions.  Therefore, the elimination of television advertising on younger children may be able to lessen the impact of materialistic values and the subsequent social pressures associated with it.

Problems and criticisms

Whilst there are several psychological and social advantages to banning children’s advertising, proposals to increase the level of regulation in the field have been met with significant resistance from the marketing industry and external stakeholders.

Since its conception, the marketing industry has claimed that advertising’s role has supported and largely subsidised the cost and availability of media to the general public. By extension, one of the biggest – and potentially unintended – consequences of banning television advertisements would be the withdrawal of funding from businesses in children’s content (DSCF, 2009: 14). However, since it is still in businesses’ interests to advertise their products, we would expect to see a gradual shift from television-based promotions towards non-broadcast marketing communications. Alternatively, state and publicly funded channels could also assist in subsidising the cost of children’s media content. For example, in December 2009, the Australian Broadcasting Corporation (ABC) launched a state-funded initiative for an advertisement-free children’s television channel called ABC3. This example demonstrates that the issue of television advertisements to children is not only one to be discussed within the marketing industry, but also has wider implications and scope for the state to play a part as well.

One of the most frequently cited arguments made by the marketing industry is that television advertising to children plays a pivotal role in the development of consumer socialisation. As defined by Ward, consumer socialisation refers to the “processes by which young people acquire skills, knowledge, and attitudes relevant to their functioning as consumers in the marketplace” (1974: 2). In other words, commercials facilitate the consumer’s – in this case, the child’s – understanding of the marketplace and allow them to develop a higher level of commercial knowledge and brand awareness from a younger age. Here, television advertising could be viewed as providing information which “helps children to make more informed decisions” and “prepares them for the real world” (Armstrong and Brucks, 1988: 101-102). Undoubtedly, consumer socialisation is important to the commercial development of a child. However, by specifically prohibiting television advertising to children under the age of seven, the recommended BCAP Code reform is a balanced compromise that still allows for non-broadcast forms of advertising, as well as radio broadcasting to children. Coupled with product branding that children are inevitably exposed to within households and shops, children are still able to acquire the necessary skills to effectively develop into an informed consumer.

Closing remarks

To conclude, this essay turns back to the question of fairness: is it fair to advertise to children who do not have the cognitive skills to understand the true intent of television commercials? Based on the findings in the above theories, children, at the age of seven or less, do not have the cognitive capabilities to process the true intent behind television advertisements. Therefore, it is deemed to be inherently unfair to advertise to them. This essay concludes that the BCAP Code should be reformed to insert a clause prohibiting broadcast television advertising directed to children less than seven years old. To ensure the integrity of the marketing industry and to uphold the Code’s spirit and responsibility to consumers and society, it is a necessary step in the right direction.

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