Step into (a compliant) Christmas

Sep 28th '23

Christmas is creeping up on us and we can feel the festive campaigns unfreezing as we speak. The Committee of Advertising Practice (CAP) don’t want you appearing on any naughty lists this year so take advice and you’ll be sweet!


  • Under Pressure

This year has been tough on everyone financially and at Christmas time in particular consumers can feel enormous pressure to spend and treat others, sometimes beyond their means. It is, therefore, advertisers’ duty to ensure that their ads are not encouraging excessive spending in an irresponsible manner using ‘buy now pay later’ credit schemes. Please read our online article for more on this.


  • Do they know the T&Cs?

When administering Christmas promotions please ensure that all significant terms and conditions are included in the ads and that the full T&Cs are made easily accessible.


Advertisers must also take care to not mislead consumers with false ‘time-limited’ promos. In 2019 PLT’s use of a countdown clock with the words ‘HURRY’ was found to be misleading as it indicated a time-limited offer, which implied consumers would be getting a savings benefit compared to the usual delivery costs, however this was not the case.


  • Be Merry, Be Responsible…

Christmas is a time for enjoying ourselves and we know that marketing campaigns for alcoholic products like to associate alcohol with Christmas time. However, Advertiser’s do have an obligation to ensure their ads are not seen to be encouraging excessive or irresponsible drinking.  In 2018 the Advertising Standards Authority (ASA) ruled that Epic Pub Company’s Christmas-time “barrow of booze” promotion was irresponsible because the ‘barrow’ constituted of up to 14 units of alcohol per person – well in excess of official recommended guidelines.


  • Think of the Children

With children writing their lists to Father Christmas asking for all the latest toys and gadgets, we understand that a lot of their inspiration can come from what they see in ads. Advertisers must ensure that any ads targeting or featuring children are not exploiting their credulity, loyalty, vulnerability, or lack of experience by making them feel inferior for not buying (or encouraging other to buy) an advertised product.


You must also make ads clear and allow children to easily grasp the main characteristics of the product shown, including any significant terms and conditions. However, you must not directly exhort them to buy, or ask someone else to buy, the advertised product or service.  We have lots of guidance on advertising to children so please feel free to treat yourself to some reminders.


Source: CAP


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