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SUMMARY
Campaign for a Commercial-Free Childhood ("CCFC")
respectfully submits these comments in response to the Federal
Communications Commission’s request for comment on the practice of
"embedded advertising." CCFC is a national coalition of healthcare
professionals, educators, advocacy groups, parents and individuals
concerned with the effects of commercialism on children. CCFC urges the
Commission to promptly adopt new regulations on embedded advertisements
in order to protect children from an advertising practice they are
cognitively unable to understand. Specifically, CCFC requests that the
FCC explicitly ban embedded advertisements in all children’s programming
as well as in all primetime broadcast programming when children are
likely to be in the audience.
Embedded advertisements are pervasive in today’s media
marketplace. Research shows that embedded advertisements have been found
to be much more effective and persuasive than traditional commercial
spots. As a result, companies have increasingly focused on both placing
and integrating products into popular programs. Embedded advertising has
potentially harmful effects on all television viewers, but children are
most at risk. Children are especially vulnerable to embedded advertising
techniques because they are cognitively unable to distinguish
advertising content from programming and cannot discern persuasive
intent. Safeguards such as sponsorship identification and other types of
disclosure are ineffective for children, who often cannot read or
understand them. Consequently, CCFC recommends that the FCC adopt
additional safeguards to protect children from the harms of embedded
advertising.
Regulators have long recognized that children should be
protected from the harmful effects of advertising. Over the years the
FCC has created special safeguards for children, including requiring
clear separation between children’s programming and advertising,
imposing
commercial time limits and prohibiting host-selling
during children’s programs. The FCC should make clear that these
existing policies explicitly prohibit the inclusion of embedded
advertising in all children’s programming regardless of whether it is
provided via broadcast, cable or satellite service.
In addition to making clear that its existing policies
preclude embedded advertising from children’s programming, CCFC remains
concerned that children are highly vulnerable to the harms of embedded
advertising during primetime broadcast programming. Many programs aired
during this time are extremely popular with children between the ages of
two and eleven and have become "must-see" family viewing. These programs
are also among those that include the most embedded advertising. In
order to more fully protect young viewers, CCFC urges the FCC to also
ban embedded advertisements in primetime broadcast programming when
children are likely to be in the audience.
CCFC's full comments to
the FCC are available here.
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