Background
Two issues were investigated, both of which were Not upheld.
Ad description
A TV ad and tweet for Bud Light Beer:
a. A TV ad seen on 13 May 2017 featured three animated frogs togethereach repeating the words “Bud” “Light” and “Beer.” The shot then panned up to show a bar with an illuminated sign “Bud Light,” followed by on-screen text which read “NOW IN THE UK”.
b. A paid-for tweet seen on 10 May 2017 stated “Look who’s hopped into town #BudLightBeer crank up the sound” and featured ad (a) embedded with a prominent play button.
Issue
The ASA received two complaints:
1. one complainant challenged whether ad (a) was irresponsible because it was of strong appeal to people under 18 years of age; and
2. one complainant challenged whether ad (b) was irresponsible because it was of particular appeal to people under-18.
Response
1. & 2. AB InBev UK Ltd t/a Bud Light Beer said that the intention of the ad was to evoke nostalgia to adult audiences who remembered the original ad from 1995 and introducing them to the new '‘Light’ frog and the light brand. Bud Light Beer intentionally based the ‘Light’ frog on a real-life Blue Poison Dart frog to keep the real life feeling of the pond. This was further achieved by depicting the frogs in their natural dark setting with limited animation and the inclusion of a bar at the end.
In relation to ad (a) Bud Light Beer said that they ensured the ad was not transmitted during or adjacent to children’s programmes or programmes commissioned for, principally directed at, or likely to appeal to audiences below the age of 18.
In relation to ad (b) Bud Light Beer said that the content would only be accessible to consumers over the age 18. Those following the @budlightuk Twitter page would have to have gone through an age gate to confirm they were over 18. They further ensured compliance by conducting demographic checks every six months to confirm that 75% of users were over 18. They provided the inclusive and exclusive targeting data they used to ensure that the ad was directed at an adult audience. This included the social demographic and audience preferences. Bud Light Beer confirmed they sought advice from CAP about the ad before it was broadcast.
In relation to the TV ad (a), Clearcast said that they felt the characters included in the ad were not of strong or of particular appeal to children and that the ad would have general appeal to all viewers. They felt that the frogs in the ad were not anthropomorphised and were instead relatively realistic visual descriptions of frogs. Further, the frogs themselves did not behave in a way that might appeal to children or make them light hearted or attractive characters. Clearcast said the nostalgia was a significant part of the appeal of the ad and that its intention was to remind viewers of the original iconic ad and that this value did not exist for anyone too young to remember the original ads.
Assessment
1. Not upheld
The ASA noted that the ad was subject to a broadcast restriction which meant it was not transmitted during or adjacent to children’s programmes, which included all programmes commissioned for, directed at or likely to appeal to under-18 audiences. The BCAP Code required that alcohol ads must not be likely to appeal strongly to people under 18 years of age, especially by reflecting or being associated with youth culture or showing adolescent or juvenile behaviour. Therefore, alcohol ads could not appeal more strongly to under-18s than they did to over-18s, regardless of when they were broadcast.
We acknowledged that talking frogs were featured in programmes and films that were targeted towards children. However, we considered that the frogs’ croaks were not anthropomorphised but were animated to sound realistic and therefore would not strongly appeal to children. We further noted that the frogs and their environment were also animated to appear realistic, with the colours being dark and background noise atmospheric. The ad was set outside a bar which, taken with the above, we considered further emphasised the overall adult tone of the ad. We therefore concluded that the ad was not irresponsible and was unlikely to appeal strongly to under-18s.
On this point, we investigated ad (a) under BCAP rule 19.5.1 (Alcohol), but did not find it in breach.
2. Not upheld
The CAP Code required that alcohol ads must not be likely to appeal particularly to people under 18, especially by reflecting or being associated with youth culture. Non-broadcast alcohol ads could not therefore appeal more strongly to under-18s than they did to over-18s. We noted from their response that Bud Light Beer had ensured that their Twitter page had an age gate so only those who entered a birth date which showed them to be over the age of 18 could follow the page. The tweet was targeted at those who were over 21, in a specific location and engaged with the brand by using their chosen keywords. Further, they selected to target Twitter users who followed similar alcohol brands and who had interests and behaviours which included ‘beer’ and ‘alcoholic drinks buyers’. We noted that Bud Light Beer had not actively chosen to exclude Twitter users based on interest information which was strongly associated with those who fell into a restricted age demographic, namely users who were under 18. We understood that all of the targeting data was directed at adults. However, we considered it could not be reasonably said that children and young people could not still be exposed to the ad. We therefore went on to consider whether the ad was of particular appeal to under-18s.
For the reasons given in point 1, we considered that the ad was unlikely to appeal strongly to under 18-year-olds. In addition, we acknowledged that the appeal of the ad was based in nostalgia for the original ad that appeared 20 years ago. We considered under-18s would not have nostalgic feelings for the old ad and that this emphasised the overall adult tone of the ad. We therefore considered that it was likely to appeal more to adults than to under-18s.
We noted that the use of animated characters had the potential to appeal to under-18s. However, for the reasons above, we concluded that the frogs and the ad did not have particular appeal to under-18s, and was not irresponsible.
On this point we investigated ad (b) under CAP rules 18.14 18.14 Marketing communications must not be likely to appeal particularly to people under 18, especially by reflecting or being associated with youth culture. They should not feature or portray real or fictitious characters who are likely to appeal particularly to people under 18 in a way that might encourage the young to drink. People shown drinking or playing a significant role (see rule 18.16) should not be shown behaving in an adolescent or juvenile manner. (Alcohol), but did not find it in breach.
Action
No further action necessary
