On September 22, 2008 CCFC filed comments for the Federal Communications Commission's Notice of Proposed Rulemaking on embedded advertising. A summary of those comments is below. The full comments are available here.
Campaign for a Commercial-Free Childhood ("CCFC") respectfully submits these comments in response to the Federal Communications Commission’s request for comment on the practice of "embedded advertising." CCFC is a national coalition of healthcare professionals, educators, advocacy groups, parents and individuals concerned with the effects of commercialism on children. CCFC urges the Commission to promptly adopt new regulations on embedded advertisements in order to protect children from an advertising practice they are cognitively unable to understand. Specifically, CCFC requests that the FCC explicitly ban embedded advertisements in all children’s programming as well as in all primetime broadcast programming when children are likely to be in the audience.
Embedded advertisements are pervasive in today’s media marketplace. Research shows that embedded advertisements have been found to be much more effective and persuasive than traditional commercial spots. As a result, companies have increasingly focused on both placing and integrating products into popular programs. Embedded advertising has potentially harmful effects on all television viewers, but children are most at risk. Children are especially vulnerable to embedded advertising techniques because they are cognitively unable to distinguish advertising content from programming and cannot discern persuasive intent. Safeguards such as sponsorship identification and other types of disclosure are ineffective for children, who often cannot read or understand them. Consequently, CCFC recommends that the FCC adopt additional safeguards to protect children from the harms of embedded advertising.
Regulators have long recognized that children should be protected from the harmful effects of advertising. Over the years the FCC has created special safeguards for children, including requiring clear separation between children’s programming and advertising, imposing
commercial time limits and prohibiting host-selling during children’s programs. The FCC should make clear that these existing policies explicitly prohibit the inclusion of embedded advertising in all children’s programming regardless of whether it is provided via broadcast, cable or satellite service.
In addition to making clear that its existing policies preclude embedded advertising from children’s programming, CCFC remains concerned that children are highly vulnerable to the harms of embedded advertising during primetime broadcast programming. Many programs aired during this time are extremely popular with children between the ages of two and eleven and have become "must-see" family viewing. These programs are also among those that include the most embedded advertising. In order to more fully protect young viewers, CCFC urges the FCC to also ban embedded advertisements in primetime broadcast programming when children are likely to be in the audience.