CARU Update: Changes To COPPA And The Food Marketing Debate

Ypulse stopped by the Children’s Advertising Review Unit (CARU) Annual Conference last week to get a handle on the updates to the COPPA rule and find out about the latest with the Children’s Food and Beverage Advertising Initiative (CFBAI) and self-regulation of food advertising. Here’s a summary to help youth marketers stay up-to-date…

Marketing To Kids Online

Phyllis Marcus from the FTC and Phyllis Spaeth from CARU walked the audience through the proposed changes to COPPA and what they mean for marketers and advertisers reaching children under age 13 online.

The intention of the updated rule is to take into account new technologies so marketers cannot exploit them to target children. One of the most recent examples of this is children accidentally making in-app purchases from their parents’ smartphones and tablets. An update was definitely in order. Here are the key proposed revisions…

The list of personal identifying information (PII) would be updated to include photos, videos, and audio recordings; geolocation information; and screen/user names that are not used to support internal operation of a website. That last change had a few audience members concerned. The FTC clarified the rule to explain that screen names used to authenticate a user are an appropriate use because it supports the internal operation of the site. Similarly, those used to deliver appropriate site navigation and maintain user preferences are acceptable.

The definition of websites directed at children would be updated to include those that use musical content that appeals to children, child celebrities, and celebrities that appeal to children. The FTC chose to reject a standard based on the percentage of users who are children because age data submitted online has proved unreliable.

The definition of collecting PII would be updated to include merely requesting, prompting, or encouraging a child to provide personal information, rather than only those sites that require children to provide such info. In addition, the 100% deletion standard, requiring sites to delete all PII before anything submitted by a child is made public would be modified to make allowances for operators that make a “reasonable measure” to do so. As Marcus explained, the FTC isn’t attempting to go after those who accidentally make a mistake, but stop those who flaunt the rule.

Websites that target children are required to disclose all operators of the site, not just the primary operator. So sites run in partnership with multiple organizations would need to list all organizations involved so parents are fully informed when their children interact with the site.

The updates to parental consent also raised concerns among some audience members. The proposed changes add electronic scans of parental consent forms, video-conferencing, and checks of government-issued IDs, but eliminates “email plus.” It is the latter proposed change that worried audience members, but the FTC explained that the method doesn’t ensure that it is a parent receiving the email and granting consent. In a later session at the conference, the FTC’s proposed change to email plus was justified as most members of a teen and tween panel admitted to having accessed their parent’s email or having acted as one of their parents online.

The proposed rule changes would also update the Safe Harbor program to require them to detail their business models and technological capabilities to insure COPPA compliance and they would be required to perform an annual audit of members to demonstrate continued compliance.

Responsible Food Marketing To Kids

The battle between the Interagency Working Group (composed of representatives from the FTC, the CDC, the FDA, and the USDA) and the CFBAI wages on, with the former proposing strict new guidelines regarding healthy and nutritious food, and the latter insisting on self-regulation.

Elaine Kolish of the CFBAI discussed the standards proposed by the CFBAI in comparison to those proposed by the IWG. As she put it, few current products marketed to children meet the IWG nutrition and healthful diet guidelines, “except canned bamboo shoots.” While the CFBAI supports the shift of food marketed to children to be healthier, the IWG proposal pushes that concept to mandate only the healthiest food — raw, unprocessed foods — be marketed to children. Under the new IWG guidelines, a third of food products that are currently considered healthy and appropriate for kids would no longer be so.

We see both sides of the argument. The obesity epidemic, which is the impetus for the proposed changes, is a considerable issue in the U.S., and children’s eating habits need to change. Limiting the foods that are marketed to them to healthy items will make a difference, but it will take more than just that to bring an end to childhood obesity.

A recent study measured children’s response to ads for fries versus apple wedges shown amid cartoons. After seeing the ads, kids were given the option to get a coupon for fries or a coupon for apple wedges. Even after seeing only the ad for apples, nearly half of children wanted fries, compared to 7 in 10 who wanted fries after seeing the ad for fries. When parents got involved and encouraged their children to choose the healthier option, about a quarter of kids in each group responded by changing to the healthier choice. Parental involvement is key to improving children’s eating habits.

Encouraging children to eat healthy isn’t always easy; most kids don’t want to eat a dinner of bamboo shoots. Parents and marketers need to work together to teach children about healthy eating while giving kids options they can enjoy.


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