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Children's Advertising Code: review of adult submissions received

On 19 April 2004, the Broadcasting Commission of Ireland (BCI) launched its Children's Advertising Code - Phase 3 Consultation Document.

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This marked the third stage of a process designed to culminate in the creation of a code on children's advertising in Ireland. This Phase 3 consultation document from the BCI is by Dr. Ruth-Blandina M. Quinn, Research Officer.


On 19 April 2004, the Broadcasting Commission of Ireland (BCI) launched its Children’s Advertising Code – Phase 3 Consultation Document. This marked the third stage of a process designed to culminate in the creation of a code on children’s advertising in Ireland. The impetus to respond to this area of commercial activity comes from the Broadcasting Act, 2001 which requires the BCI to identify set standards to govern advertising and related practices aimed at children. When finalised, the code will be the first of its kind in Ireland.

The practical application of the children’s advertising code will affect home-based broadcast media exclusively. It will apply equally to public and private broadcasters in Ireland. In addition, it will apply to those who make use of a frequency or satellite capacity or up-link in Ireland. More specifically, it will apply to RTÉ radio and television services, TG4, to those television and radio stations licensed under the Radio and Television Act, 1988 (including the national broadcasters, TV3 and Today FM) as well as content contractors licensed by the BCI under the Broadcasting Act, 2001. It will not apply, however, to those services received from abroad – for example, Nickelodeon and MTV – which remain subject to the rules and regulations of their country of origin.

The scope of application may be limited but the number of influences being brought to bear on the process is not. Phase 1 of the process marked the release of the first consultation document to the public accompanied by an advertisement in the national press inviting people to participate. Phase 2 Consultation Document was designed to continue raising public awareness vis-à-vis the development of a children’s advertising code. In addition to the circulation of materials to groups, representative organisations and industry related bodies, the public was invited, through a series of advertisements in print and broadcast media, to participate in the second phase of the process. Participants could reply by post or on line at the BCI’s website. The BCI sought to invite and to accommodate diverse opinions while also being able to facilitate pertinent new material arising in the process. In addition, children were consulted – firstly, through the release of a document specifically designed for a child audience and secondly, through a children’s event which took place in Croke Park, Dublin on 24 January 2004.

The process for developing the code is divided into three principal parts. Information gathered and reviewed in the first two phases fed directly into the third, and final, phase. Once again consultation with the general public, children and key organisations underpinned this stage in the process of developing the children’s advertising code. In Phase 3, the BCI produced a draft version of the code based on views expressed in the Phase 1 and Phase 2 consultative processes and the Commission’s own decisions arising directly from these processes. This draft code was made available to the public and all interested parties for comment and discussion. Advertisements were placed in the national press inviting all to participate. Viewed collectively, this emphasis on consultation, participation and inclusion indicates that the ultimate aim of the process is to devise a code which is feasible, easily applied and representative of views expressed.

Consultation document

Similarly to the other consultation documents, a series of questions was posed in Phase 3 Consultation Document. It is therefore advised that the document be read in conjunction with this Review of Adult Submissions.

Material reviewed in this document emanated from adult responses to the Phase 3 consultation exclusively. A child friendly version of the children’s advertising code was produced and circulated on request to schools which had participated in Phase 2 of the consultative process and to those children who had attended the children’s event in Croke Park in January 2004.

Present report

This report summarises information submitted by adults in response to the Phase 3 Consultation Document. The approach taken is linear. It outlines the relevant section of the BCI draft code, specifies the question asked and the information received under fifteen principal headings. These form the sections which follow:

  • Social values
  • Inexperience and credulity
  • Undue pressure
  • Special protection for children in advertising
  • General safety
  • Violence
  • Diet and nutrition
  • Parental responsibility
  • Programme characters
  • Product prohibitions and restrictions
  • Identification and separation
  • Insertion of advertising
  • Scheduling children’s advertising
  • Assessment
  • Code administration

Approach taken

The approach taken to the consideration of submissions was systematic and analytic. As this was a general call, all representations were afforded equal weighting. Each individual submission was counted as one irrespective of the numbers represented therein. Representations made by individual members of key organisations were counted separately. The method applied allowed for a thorough appraisal of information received in terms of respondent’s objectives, context and content and his/her overall contribution to the code currently being developed.

The format of this review differs somewhat from those issued in Phases 1 and 2 albeit having some common ground. Similarly to those documents, it reacts to the nature of the material provided but in this instance, the type of material submitted differed significantly. The following details must therefore be taken into account. Approximately 950 English language versions and 65 Irish language versions of the Phase 3 – Consultation Document (adult) were requested and/or sent to relevant organisations and individuals. Through the BCI website, email and post, 121 adults chose to comment on the contents of the BCI draft code.

The majority of those responding were interested parties, those whose work will be directly affected by the implementation of the finished code. In addition, no single submission or respondent dealt with every section. Information was sought on all categories but respondents were also invited to respond to individual sections if desirable. As a result, some questions attracted considerable attention – for example, the section on ‘Diet and nutrition’ – while other sections – for example, on ‘Code administration’ – was referred to by just a few. Unlike reviews produced on the other two phases, concluding remarks are not provided in each section but general conclusions are drawn at the end of the report.

This report deals with specifics. It records specific comments to specific clauses of the draft code. It does not detail opinions for and against the general topic of children’s advertising but has at its core the analysis of the BCI draft code in light of comments made. Representing such opinions was the purpose of review documents released after Phases 1 and 2.

In the third Phase, it was inevitable that those affected by these rules would respond in greatest numbers. Those who were generally supportive of the provisions signalled their endorsement. In some instances, however, they did not provide detailed responses as it was often assumed that material submitted in earlier stages would influence the outcome.

Other respondents made quite detailed responses to the provisions of the Draft Code. It should be noted that in criticising certain elements, many respondents suggested alternatives. They engaged in the process, using their own experience to build on, rather than merely rejecting, what the BCI had proposed. Where differing opinions were provided, these were duly recorded. Context is of particular importance in this respect. Consequently, it is advised that this review of submissions made in Phase 3 be read in conjunction with review documents produced during the first and second phases.

The reporting style of the document is informative rather than analytic. It aims to record rather than to advance/discuss suggestions made. Where additional comments and/or observations were made by respondents, consideration was given as appropriate. Viewed as a whole, this document should be seen as part of the overall process in the development of the code for children’s advertising rather than a stand alone report.

Phase 3 is the culmination of the process. Information supplied, and comments made, during all phases of the process combine to influence the final code. Throughout no one voice was perceived as louder than any other.

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