BBB National Programs Archive

CARU Recommends Ubisoft Holdings Refrain From Marketing “Avatar” Video Game To Children Under The Age Of 12

New York, NY – Dec. 9,  2010 – The Children’s Advertising Review Unit (CARU) of the Council of Better Business Bureaus, Inc., has recommended that Ubisoft Holdings, Inc., refrain from marketing the Teen-rated video game, “James Cameron’s Avatar: The Game” directly to children under the age of 12.

Broadcast advertising for the game came to the attention of CARU through CARU’s routine monitoring efforts. The advertising at issue appeared on the CW 4Kids programming block at 11 a.m., during the program, “Teenage Mutant Ninja Turtles.” The game is rated “Teen,” for mild language, mild suggestive themes and violence.

As a preliminary matter, CARU’s guidelines make clear that content that is inappropriate for children should not be advertised directly to them and that video games that are rated for a certain age group, should not be advertised to children who are younger than the age specified.  CARU has consistently taken the position that video games rated “Teen” should not be advertised to children under 13.

The advertiser argued that it had distributed the challenged commercial in good faith, based on data provided by its advertising agency and the programmer, reflecting that 70% of the viewing audience for the TMNT show was 12 years of age or older.

In determining whether an advertisement is directed to children under the age of 12, CARU considers a number of factors, including whether the content of the media in which the advertisement appears is intended for children under 12, whether the advertisement appears during, or just before or after, what is generally understood to be children’s programming, whether the advertisement appears during, or just before or after, a television program which is counted towards the broadcaster’s or cablecaster’s Children’s Television Act obligations; and whether the advertiser intended to direct the advertisement primarily to children under 12.

After examining each of these factors, CARU determined that placement of the advertising in the TMNT show in Saturday morning programming in the CW 4Kids network constituted advertising primarily directed to children. CARU recommended that advertising for the “Avatar” video game should not be directed to children.

In its advertiser’s statement, the company said that the challenged commercial has been discontinued and noted that it does not intent to appeal CARU’s decision.