New York, NY – May 27, 2009 – The Children’s Advertising Review Unit of the Council of Better Business Bureaus (CARU) has recommended that Crayola include an audio disclosure to broadcast advertising for its “Color Explosion 3-D” product to better assure that children understand what is included in the initial purchase.

The advertising at issue came to the attention of the CARU through CARU’s routine monitoring of advertising directed to children.

The “Color Explosion” product comes in two versions, one with standard size black paper, and one with wider black paper.  Both versions include the paper, special markers, and 3-D glasses with which to view the finished pictures.  The only difference between the two versions is the size of the paper included.

The commercial featured children creating designs on the black paper with “Color Explosion Board Tip Markers.”  The final screen shot features both versions of the product, each in a separate box.  The shot also featured a pad and paper, four markers, and the 3-D glasses. At the bottom of the screen was a small visual disclosure – in gray type against a white background – that stated, “each sold separately.” 

It is well-established that an advertiser is responsible for all reasonable interpretations of its claims and not just the messages it intended to convey.  After carefully reviewing the advertisement, CARU determined that one reasonable take away message was that the two different paper sizes depicted in the commercial were included in the purchase of one set. 

CARU further determined that the super did not sufficiently convey to a child audience that it was necessary to purchase both sets to receive both paper sizes. 

Further, CARU noted, it has routinely held that an audio voiceover should accompany a written disclosure in advertisements directed to children, because younger children may not be able to read or otherwise understand a written disclosure.

CARU recommended that a separate audio disclosure be added to inform children that the standard paper version and the wide paper version must be purchased separately. 

Crayola, in its advertiser’s statement, said the company appreciated the opportunity to participate in the CARU process.  The company noted that although it “views the facts and circumstances of the instant case differently than CARU,” it will take CARU’s decision into account if it plans to re-run the advertisement.