CAP and BCAP explain that the pandemic saw QR codes in widespread use as smartphone-linked technology, such as “track and trace”, helped in the fight against COVID-19. Although QR codes have been around for many years, their use had never been so widespread in daily life. Advertisers are now following-up on this trend.

CAP and BCAP explain that using codes in ads means campaigns can instantly take consumers from an originating ad in virtually any media to further information about products and promotional offers. Although they are a perfectly legitimate direct response mechanism, QR codes present potential compliance issues that marketers need to be aware of, the Committees say, as they could be used in ways likely to mislead consumers or to promote unacceptable products or those inappropriate for younger audiences.

Use of QR codes in ads must therefore conform to the UK Advertising Codes’ misleading advertising rules. Marketers must avoid scenarios where a consumer could be misled into enquiring further by scanning a QR code, if the ad does not appropriately set consumer expectations over what they are accessing. This may be through the omission of material information or giving a misleading impression about the content a QR code links to. For example, ads should not suggest a product variant is available when it is not and make clear the extent of financial commitments such as non-optional charges.

Another risk is that QR codes might breach CAP or BCAP’s sensitive product category rules. There are dedicated rules for alcohol, gambling, lotteries, e-cigarettes and HFSS food and soft drink products, that prohibit ads from being placed in media for children and young people or other media where they are disproportionately present in the audience. The ASA will consider the wider context in which an ad appears, including where any links within an ad lead to. A brand ad without specific product references that links via QR code to a sensitive category product will be banned if it’s placed in media covered by these rules.

As with sensitive product categories, QR codes should not be used to take younger viewers to content that is scary, sexualised or otherwise inappropriate. A good example is an ad including a short movie trailer, which links through to a fuller version including such content. To read the advice note in full and for links to further information, click here.