Background
Summary of Council decision:
Two issues were investigated, both of which were Not upheld.
Ad description
An animated cinema ad, shown before the U-rated film 'Monster's University' at 4:30pm, featured Coco Pops equity brand characters working in a mine. Coco the Monkey said "The gang and I were drilling for Coco Rocks when ...", followed by footage of the character Croc appearing at the mine entrance and shouting "They're mine now, monkey!". The gang looked scared, and Coco said "Quick, pass me some Rocks. Brace yourself Hippo". The gang fired pieces of the cereal at Croc. The first piece hit Croc's chest and broke into two pieces. Ostrich exclaimed "That was a soft one". Coco said "Pass me a crunchy one". Ostrich passed Coco another Rock, and fired it at Croc. The Rock hit Croc in the chest and he flew backwards out of the mine. Coco and Hippo were shown eating from bowls of the cereal as Coco said "Croc will never get his claws on our tasty Coco Rocks". On-screen text shown during part of the ad stated "Enjoy as part of a varied diet & active lifestyle. 30g = 9% GDA for sugar".
Issue
The complainant challenged whether the ad:
1. condoned or encouraged poor nutritional habits or an unhealthy lifestyle in children; and
2. disparaged good dietary practice.
Response
1. & 2. Kellogg Marketing and Sales Company (UK) Ltd t/a Kellogg considered the ad did not contain any messaging, whether within the voice-over, storyline or imagery, that could be said to condone or encourage poor nutritional habits or an unhealthy lifestyle in children, or to disparage good dietary practice. They highlighted that the ad featured on-screen text which stated "Enjoy as part of a varied diet & active lifestyle. 30g = 9% GDA for sugar". They said eating breakfast regularly was recommended by dietitians and policy makers as an important part of a healthy diet, and that encouraging the "breakfast habit" was important to them as a company. They said that a wealth of scientific research showed that eating breakfast regularly gave rise to a host of health benefits. They understood that despite that, one in seven schoolchildren skipped breakfast every day.
Kellogg said Coco Pops Rocks was a source of fibre, six B vitamins, iron and vitamin D, and when eaten with milk, added protein and calcium to children's diets. They said the product contained 8 g of sugar per 30 g bowl, which equated to 9% of the Guideline Daily Amount (GDA) of sugar for children aged five to ten years old. They said the CAP Code did not include restrictions on the advertising of foods high in fat, salt and sugar (HFSS foods) to children, including in cinema ads. They highlighted that they did not hide the amount of sugar in the product, which was demonstrated by the inclusion of that information in the ad's on-screen text. They said all their foods carried nutritional labelling in order that parents could decide whether or not to purchase their products.
Assessment
1. & 2. Not upheld
The ASA noted the CAP Code required that compliance with the Code be assessed according to an ad's probable impact when taken in context, including the medium in which it appeared, the audience and its likely response, and the nature of the product. We considered that in the case of a cinema ad, various factors were relevant to the probable impact of the ad in context, including the likely composition of the audience as a result of the type of film before which it was shown and the time of day at which it was shown, and how that audience would respond to the ad and its references to the product advertised.
We considered it likely that the film 'Monsters University' would have had particular appeal to children, and therefore that children (defined in the CAP Code as those under 16 years of age) would have formed a significant proportion of the cinema audience, particularly in relation to the screening seen by the complainant which was at 4:30 pm during a school holiday. We considered the cartoon-style, the animal characters and the storyline of the Coco Pops "gang" working together to defeat an enemy would be of appeal to children, and younger children in particular, as would the ad's descriptions of the different types of "Rocks" in the cereal as "soft" and "crunchy" and the product as a whole as "tasty". We considered the ad, and the advertised product, would be of particular appeal to children.
We noted the ad included on-screen text that stated the percentage of a child's (aged five to ten years old) GDA of sugar contained in a 30 g serving of the cereal, and that the product should be enjoyed as part of a varied diet and active lifestyle. However, we considered that many children would not have the reading comprehension skills or relevant knowledge to be able to interpret and understand the information about the sugar content of the product and that it should be eaten as part of a varied diet and active lifestyle. We also considered that, in the context of the exciting action in the visuals of the ad, it was unlikely that even those children with the ability to read and understand the on-screen text would pay attention to the information, which was contained in small print at the bottom of the screen. We considered the information in the small print was unlikely to mitigate the appeal of the product to children in the audience, or make clear to them that the product should only be eaten in moderation.
Notwithstanding that we considered the ad and the product were likely to appeal to children, we considered the ad did not include any content which condoned or encouraged poor nutritional habits or an unhealthy lifestyle, or disparaged good dietary practice. The ad included only one brief shot of two of the characters holding bowls and eating a mouthful of the cereal. There was no suggestion that it was appropriate to consume the product frequently or in excess or that an inactive or sedentary lifestyle was better than physical activity. We concluded the ad did not breach the Code.
We investigated the ad under CAP Code (Edition 12) rules 15.11 15.11 Marketing communications must not condone or encourage poor nutritional habits or an unhealthy lifestyle in children. and 15.12 15.12 Marketing communications must not disparage good dietary practice or the selection of options, such as fresh fruit and fresh vegetables, that accepted dietary opinion recommends should form part of the average diet. (Diet and Lifestyle), but did not find it in breach.
Action
No further action necessary.
