May 22, 2020
All advertisers are aware of the need to protect vulnerable groups from exposure to certain types of advertising. In particular, ads for certain age-restricted products like alcohol and gambling should be scheduled and placed appropriately to ensure that the exposure of children (those aged 15 and under) and young persons (those aged 16 and 17) is limited. There are also rules within the advertising codes that specifically prohibit these certain types of ads from appearing in children’s and young people’s media and even when they are targeted at a predominantly adult audience, ensuring that they do not appeal particularly to the under-18s.
In 2018, the ASA reported on children’s exposure to age-restricted TV ads generally (i.e. it included exposure to ads for foods and soft drinks high in fat, salt and sugar (HFSS) as well as to alcohol and gambling). Today, the ASA has published an update to this, which because of further government consultation on HFSS advertising, just looks at the latest figures on the exposure of children to alcohol and gambling ads on TV.
In summary, children are being exposed to fewer ads generally, with their exposure to alcohol ads between 2008 and 2019 decreasing by two thirds (an average of 0.9 ads per week last year) and their exposure to gambling ads has remained at similar levels throughout the same period (the 2019 weekly average being 2.5) but the data does confirm: (i) that children’s exposure levels rose slightly in 2018, largely due to an increase in sports-based gambling products; and (ii) that adults (which this report unhelpfully categorises as 16+) have had steadily increased exposure to gambling ads since 2008 (the first full year in which all gambling products could be legally advertised on television), albeit that the 2019 figures show a decline on 2018.
Whilst that might suggest that gambling operators have further to go to reduce children’s exposure to their ads on TV, it is important to view this through the context of overall exposure – gambling ads are around 2% of all the TV ads children see and bingo, lottery and scratch card products continue to make up the majority of the ads in this category. Whilst ads for casinos and then sports-related gambling follow, in 2019 children saw an average of 0.5 casino ads and 0.3 sports-related gambling ads on television each week. This figure for sports-related gambling products, in particular, is at a record low. By way of comparison, the weekly average number of ads for toys that children were exposed to on TV in 2019 was around 25.
It’s important to remember that this just reflects ads on TV and that we would need to include online and other data in order to create an accurate ‘overall exposure’ figure. There is also a potential for the ‘adult’ data to be misconstrued given that adults here include young persons, despite the fact that the age-restriction on alcohol, casino and sports betting products is 18+. But this data is useful in response to sensationalist headlines that seek to criticise gambling operators for their TV advertising presence and its harmful effect on children. Those headlines are often targeting operators of casino or sports betting products – yet this data suggests that the number of those particular ads seen by those under the age of 16 was fewer than that for alcohol last year – but, in fact, if gambling ads are to be significantly reduced to a level which is more comparable to that of alcohol ads on TV, the biggest impact is going to come from a reduction in bingo, lottery and scratch card ads that children are exposed to. Of course, this balance may be redressed if we were able to see in the exposure of such ads across all media but without that, all we can say with certainty is that children, below the age of 16, are not being exposed to an increasing amount of harmful advertising on TV.