By Paul Burrows, Senior Teleshopping Clearance Executive
It’s been almost 40 years since E.T. the Extra-Terrestrial landed on earth and gave All Hallows Eve a much-needed re-boot. Annual UK retail spending around Halloween now tops £400 million on themed home décor, clothing, confectionery and food. Naturally, increasing numbers of advertisers want to haunt your TV screens with their themed ads – so here’s a blog to help you along the way.
Dial down the scare factor
It’s counter-intuitive for advertisers to want to frighten their customers away let alone cause them harm, meaning, it’s unusual for an advert to catch the attention of the ASA. Most people know that adverts can’t contain anything that will cause physical, mental, moral or social harm to under 18s. But adults are protected too – adverts must not cause serious or widespread offence against generally accepted moral, social or cultural standards. To reach the widest possible audience and cause the least offence, you should dial down the threat level to the equivalent of certificate 12 – so best not ask Ben Wheatley or Eli Roth to direct.
Small children are particularly sensitive to mildly scary images, especially if accompanied by eerie music or fast cuts. Clearcast might apply a code (32) to alert broadcasters who might want to review the content to determine its acceptability to air around programmes appealing to under 10s. Exaggerated or deformed facial features such as skulls, zombies or even witches can be upsetting for small children and are unlikely to be allowed, even if presented in a light-hearted fashion. Unlike TV programmes, the same advert appears many times in a single day and sometimes when you’re least expecting it – which is why the rules for programming and advertising are different.
Themed fairground rides are increasingly popular, but you would be batty not to identify any significant exclusions and limitations such as age/height restrictions.
Your advert must not include visual effects or techniques that are likely to affect anyone watching with Photosensitive Epilepsy. Have a spook at Ofcom’s Guidance Note on Flashing Images & Regular Patterns or visit our killer website- OnlineFlashTest.com.
Slashing your prices?
It’s important to know the difference between the genuine Vincent Price and the genuine previous price. The higher price for a product should be charged for a longer period of time than the new, promotional price.
If you are selling treat bags or children’s masks for example, then do not use qualifiers such as “only” or “just” to make the price seem less. This rule is imperative if you are promoting costumes for children or adults.
Do not use “from” and “up to” to exaggerate the availability of a product at a given price. The CTSI Guidance for Traders On Pricing Practices states you should only make these claims if the maximum reduction quoted applies to a significant proportion of the range of products that are included in the promotion. The current working definition is 10%. To avoid getting into toil and trouble, make sure references to “from” and “up to” are shown in your voice-over or on-screen. Promotions for supermarkets offering a range of Halloween merchandise frequently get caught out by this.
Trick or treat this year?
And now for the shock ending. In line with current policy, Clearcast won’t be actively discouraging trick-or-treating on the small screen this year. Unless your script is referencing the pandemic or Government safety guidelines either directly or indirectly, then it is fine to show normal behaviours. Expect to get monstered however if your advert openly invites or positively encourages viewers to flaunt the Covid-19 Government rules. We know this is a sensitive area and the policy is under constant review; however, the context of each ad will be key to any decision we make.
If in doubt, please don’t be scared to ask your Clearcast contact.