Parents for Ethical Marketing is among fifty health, media and child advocacy organizations and professionals (including the American Academy of Pediatrics, Common Sense Media, Benton Foundation, Consumer’s Union, Center for Media and Democracy and Free Press) sending a message to FCC Chairman Julius Genachowski: Take action on TV product placement.

The coalition letter follows industry reports of increasing proliferation of product placement (branded props) and product integration (scripted ads woven into the plotline) since the FCC conducted a proceeding on the matter last fall. 

“People notice products and brands in TV shows, but they may not realize that advertisers are scripting dialogue, story plot points and even whole episodes to influence consumer attitudes and behavior,” says Josh Golin, Associate Director of Campaign for a Commercial Free Childhood (CCFC), a coalition group. Networks and producers are slyly selling off program minutes – in other words, letting sponsors write the script.

“Children who are trying to find their place in the world and have not yet developed the cognitive ability to discern persuasive intent, are particularly vulnerable to these influences and need the protection afforded by FCC disclosure and child protection rules,” says Dr. Michael Rich, director of the Center on Media and Child Health at Boston Children’s Hospital, a coalition signatory, and associate professor at Harvard Medical School.

The FCC’s proposed rule changes reflect a longstanding legal and ethical principle: People have a right to know when they are being advertised to, and by whom. Urging Chairman Genachowski to take action, the coalition is calling for:

– Clear and effective disclosures.
– Extension of the rules to cable and satellite networks.
– A ban on product placement in shows for children under 12.
– Rigorous enforcement to curb stealth, embedded ads.

Coalition Calls on FCC To Crack Down on Product Placement (Broadcasting and Cable)
Consumer Groups to FCC: Fix Product Placement (The Wrap)

The Target Corporation is tossing more of their five-percent-of-revenues back to our community in the form of the Target Children’s Book Festival ”to help foster children’s love for reading as a fun and recreational activity.”

“Target understands the importance of cultivating a love of reading in children at an early age,” said Laysha Ward, president, community relations, Target. “By taking advantage of this free, local event, Twin Cities-area families will be able to share a fun and educational experience together.”

Target also understand the importance of using an “educational” event to encourage kids to watch more television. And to want more stuff. From Target.

At a glance, the September 12 event at Three Rivers Park District’s Hyland Lake Park Reserve appears to be a fun afternoon in the park, celebrating books and listenting to live kids’ music.

Upon closer inspection:

Two of the events feature Nickelodeon brands: Characters from Yo Gabba Gabba! and Jade-Lianna Peters, voice of Kai-lan on Ni Hao, Kai-lan. I can only guess that Peters must be a Hannah Montana in the making. There’s no other reason for her to be appearing at events except to promote future Nickelodeon brands. Nickelodeon means, of course, lots of associated brand toys and products — conveniently available at Target — and extensive branded websites for kids, complete with ads for other products and more shows with their own products.

Another event not even remotely connected to books is the title character from Disney Playhouse’s Choo-Choo Soul. Disney: The juggernaut of marketing to kids. Somehow, when I think of Disney, I don’t picture a parent and child quietly reading together.

Most questionable in the lineup may be Hip Hop Harry, a character from Discovery Kids network. If kids want to learn more about Harry online after the event, they’ll find his website features a banner ad with a bouncing pink-wrapped present and the words This mystery gift could be yours! Click here to see what it is! The click leads to an ad offering TWO FREE IPOD NANOS. (Note: Since writing the draft of this post, this banner ad has changed. So you’ll have to take my word for it.)

I know that criticizing a corporation that funds community programs — especially Target — is looking a gifthorse in the mouth.

But if Target wants us to take their community outreach seriously, they probably shouldn’t be encouraging children to watch television at an event meant to get kids to read. Because children who watch more television have lower reading comprehension scores over time than those who watch less. (Source).

An alternative for September 12: Play in a local park. Sing. Go to the library. And read to your kids.

Photo courtesy echoforsberg.

Sarah Haskins does it again with Target Women: Lady Friends. Watch through to the end for an example of how girls are indoctrinated into the beautiful women-mindless consumers culture:

My daughter has a passion for fashion.

You may recall that my bespeckled seven-year-old once told me that she would have a Bratz-themed party when I died.

She’s always been a bit more, well, girly than my older daughter. She wants to paint her fingernails. She wants to wear makeup. She wants her clothes to be “cute.”

I thought that a few more years with me as her mother would knock some sense into her. But recently I’ve realized that I’ve got a real problem on my hands.

First, she announced that she wanted to be a fashion designer when she grew up. And she began designing. Matching girl and pet outfits. And accessories.

A darling outfit! With lips everywhere! Titled — in case you can’t read it – “Boy Attraction Fashion!”

Blink. Blink. 

Look what the universe did to you, a friend of mine commented.

She’s always drawn strict distinctions between what boys are like and what girls are like. Recently she told me that she isn’t “100 percent girl” because she likes to be active.

Instead of exploding, I calmly asked her to clarify. We ended up having a long discussion about gender traits. To illustrate, I drew a line along a sheet of paper with “boy” on one end and “girl” on the other. Then I gave her some words and asked her to write them in the appropriate spot on the spectrum.

In the center — halfway between boy and girl, she placed smart, responsible, and funny.

Phew.

By boy she wrote fast, strong and active.

And by girl she wrote fashion and beauty. Beauty, she said, meant that you are beautiful.

Then she mentioned that there was one other characteristic you had if you were “100 percent” girl:

One-hundred percent girls are mean.

She has also told me, while looking in the mirror, that she thinks she is fat.

WHOSE DAUGHTER IS THIS?

Pretty strong evidence, I’d say, for a wider cultural influence than what is provided in the home. She very rarely sees commercial television. We don’t have cable. There are no women’s magazines — and affiliated ads — in our house.

Some of these tendencies are, of course, hard wired. It’s part of who she is. And these certainly aren’t the only thoughts that define her. But how, in this day and age, can she really believe these things?

And how can I help her see that these media-driven female stereotypes are, well, bullshit?

Before it’s too late?

You have some extra time to let the FCC know how you feel about embedded advertising in children’s television – the reply comment period has been extended until November 17.

A recent reply comment sums up the issue pretty well:

both as a parent (of a 6 year-old and a 1 week-old) and as a professional psychologist and neuroscientist, it’s obvious that commercial content is not separated from program content in the minds of young children. Please act to confirm, enforce and require the mandated separation of commercials from any programming whose audience is likely to include children under 8, as a minimum.

In other FCC news, Commissioner Adelstein has called for a ban on interactive advertising targeting children.

Image courtesy johnb2008

This is our last chance to speak up about embedded advertising is children’s television.

As part of the larger issue of new rules for embedded advertising (or product placement) in television programs, the FCC is considering what to do about children’s programming. (Background here and here.)

The FCC accepted inital public comments and is now accepting reply comments. Reply comments are due this Wednesday, October 22.

Here’s the deal: The Children’s Television Act of 1990 states that during children’s programming, there must a separation between the commercials and the program (important because, as we know, children “below the ages of 4–5 years do not consistently distinguish program from commercial content, even when program/commercial separation devices . . . are used.” And even then, “most children younger than 7–8 years of age do not recognize the persuasive intent of commercial appeals.”)

Therefore embedded advertising by its nature violates the Children’s Television Act.

So all the FCC needs to do is clarify that embedded advertising in children’s programming violates existing laws and then enforce those laws.

Ask the FCC to enforce the Children’s Television Act of 1990 by sending a Reply to Comments. Instructions are at the end of this post.

In the comments submitted by the Campaign for a Commerical-Free Childhood (full, summary), they also recommend:

that the FCC prohibit embedded advertising in primetime broadcast programming during those hours when children are likely to be in the audience.

We’re looking at you, American Idol.

I reviewed the comments — all 166 of them. More than eighty-five percent supported changes to current product placement disclosure rules (for adult programming). Most of those comments (ninety-four percent) came from individuals. Of the comments that supported leaving the rules alone, eight out of the ten came from groups, not individuals, including the American Advertising Federation, CBS, Fox Entertainment, the MPAA, NBC, Viacom, and of course, Disney.

Commenters that supported changes to the rules included the Center for Science in the Public Interest, the Children’s Media Policy Coalition, the Writer’s Guild of America-West, the Screen Actors Guild, and N.E. Marsden.

I was especially interested in the comment from Korby Siamis:

. . . I was fortunate to have a career as a writer and producer for over 25 years. I am proud of the shows I worked on, shows that left a significant imprint on American culture. I was one of the original four writers on The Cosby Show. I was a writer and producer for Murphy Brown for eight years, ultimately serving as Executive Producer. . . .

During my career, there was a clear distinction between art and advertising. On occasions that we used a product name, we would receive notices from the network Standards and Practices department. If the reference were necessary for the joke, it would stay. Otherwise we would take it out.

. . . The concept that we would ever have been expected to include product names or usage in our writing would have been beyond ludicrous, and would have been strongly fought as the worst kind of assault on our creative process. There is no quicker way to strip writers of their integrity than to make them answer to the dollar instead of their muse.

Now my television experience is that of a mother, concerned with what her children watch. I can (and do) determine which series are appropriate for my children. But the use of product placement is a more insidious force that challenges my parenting. The distinction between entertainment and endorsement is lost on my children. Short of watching every show they watch and talking to them whenever the unexpected product placement occurs, my ability to monitor this unwanted input is undercut.

How did this change take place? Why is such devolution allowed to occur? I strongly urge the FCC to use its power to reverse this trend.

Hers was one of only a handful of comments that directly addressed the issue of children’s programming. Add your voice.

It’s easy to file a comment. It doesn’t have to be formal or lengthy or especially eloquent. Go to the FCC website, type in Proceeding number 08-90, and select Reply to Comments for number 12, Document Type.

On the upcoming makeover of Dora the Explorer, to make her appear older and more feminine: 

Nancy Zwiers, chief executive of Funosophy, a children-focused marketing firm, said the challenge for Nickelodeon and similar networks was that children were migrating to more mature programming earlier.

“The younger kids enter into a franchise, the younger they leave it,” she said. Hannah Montana, originally aimed at children aged eight to 12, was increasingly popular among viewers half that age, Ms. Zwiers said. 

On why Disney is making mobile phone applications for preschoolers:

Disney hopes some of its customers will literally cut their teeth on its mobile products: Inspired by the success of multimedia toys from companies like Baby Einstein, Disney is considering making mobile applications for preschoolers. [Executive vice president of business development and operations for the Walt Disney Internet Group Larry] Shapiro notes that young children love to play with cell phones and busy parents may want a mobile “digital pacifier” to entertain them while on the go. (via)

On why Sears is selling virtual clothing online:

Teens and tweens are making more and more of the purchase decisions, or at least influencing that decision. Mom already knows that Sears provides trusted value and quality, but we need to prove to the teens and tweens that we have the apparel and styles to help them “arrive” at school this year with confidence. . . . And as we continue to expand our outreach to the tween demographic it is increasingly important to expand our marketing strategy to include the mediums where tweens are spending most of their time.

Related posts:
Marketers would like a branch on your family tree
Your heard it here first . . . uh, second: Parents, are you Tweenabees?
A sexualized Miley Cyrus? One word: Disney.

Good news: The FCC will be taking public comments regarding product placement rules on television.

While others throw in their two cents (Nanny state! Thought police! Does the FCC really think we’re stupid?!), we’ll concentrate on children’s television, program-length commericals, embedded advertising and the Children’s Television Act of 1990.

From the FCC:

We also invite comment on whether the Commission’s existing rules and policies governing commercials in children’s programming adequately vindicate the policy goals underlying the Children’s Television Act and Sections 317 and 507 with respect to embedded advertising in children’s programming. If commenters believe that these rules and policies do not do so, we invite comment on what additional steps the Commission should take to regulate embedded advertising in programming directed to children. For example, we note that embedded advertising in children’s programming would run afoul of our separation policy because there would be no bumper between programming content and advertising. Should that prohibition be made explicit in our rules?

Comments from Commissioner Michael Kopps:

. . . [I]t is my strong initial belief that embedded advertising in children’s programming is already prohibited because it would run afoul of our existing requirement that there be adequate separation between programming content and advertising. The Commission’s existing policies in this area—which also include a ban on host-selling and tie-ins on children’s programming—target those practices that unfairly take advantage of the inability of children to distinguish between programming and commercial content. I hope we can move quickly to clarify our rules in this area as necessary and to take any appropriate enforcement action.

Comments from Commissioner Jonathan Adelstein:

After more than three years since I originally called on the Commission to update our sponsorship identification rules and to clarify the application of these rules to children’s programming, I am pleased that we are finally seeking comment on what additional steps the Commission should take. Just this month, I have spoken twice about the urgency to move this item forward and explained the need for the Commission to protect our children from marketers’ efforts to prey upon their unsuspecting minds. Despite longstanding majority support, including Chairman Martin’s commendable leadership, the release of this Notice has suffered from almost unprecedented delays. The Notice takes an important step in addressing the concerns that parents, experts, and I have been voicing for years about the unhealthy messages American media are feeding our kids. Children under the age of eight simply do not recognize that ads are trying to persuade them and tend to accept them as true and unbiased. . . . Because children are ill-equipped to identify advertising, especially when it is embedded in a program with their favorite character, we need to review and update our sponsorship identification rules. Those of us who areconcerned about children need to show leadership, not footdragging, in addressing these practices.

All emphasis mine. We’ll let you know when public comments are being accepted. Should be soon.