BBB National Programs Archive

CARU Recommends Wobble Works Modify Broadcast Ad for 3Doodler Start Pen to Better Disclose What’s Included with Initial Purchase

New York, NY – Feb. 10,  2017  – The Children’s Advertising Review Unit (CARU) has recommended that Wobble Works, Inc., the maker of the 3Doodler Start Pen, modify broadcast advertising that doesn’t clearly disclose how much “Eco-plastic” filament  is included with the initial purchase of the product.

CARU, an investigative unit of the advertising industry’s system of self-regulation, monitors advertising directed to children in all media and across all platforms. CARU is administered by the Council of Better Business Bureaus.

In this case, the commercial showed two children using the 3D pen to create detailed models of buildings, structures, figures and objects.   In one scene, a table is filled with 3D creations including a bridge, a clock tower, ferris wheel, Eiffel Tower, the Empire State Building and other structures.  The final shot in the advertisement featured more than 30 3D creations.

The basic 3Doodler Start Essentials Pen Set comes with two packs of Eco-plastic, enough to produce approximately two of the larger structures featured in the commercial.  It is not clear how much additional plastic would be required to recreate all the structures that appeared in the advertisement. Although it is not uncommon in children’s advertising to show multiple sets or items within a line of toys, in order to avoid confusion, CARU’s guidelines provide that advertisements should clearly disclose what is included with an initial purchase.

Here, the advertiser contended that the advertisement was intended to give the viewer an idea of the breadth of the creations that could be made using the product and argued that it would be unreasonable for even a child viewer to assume that all of the creations featured in the commercial could be made with a single kit.

When determining whether an advertisement leaves a misleading impression, CARU assesses how a reasonable child in the intended audience would interpret the message.  Where no consumer perception evidence is supplied by an advertiser, CARU routinely steps into the shoes of the child-targeted audience and uses its experienced judgment to determine the reasonable messages conveyed.

After carefully reviewing the advertisement and all the evidence on the record, CARU determined that one reasonable take away message was that the basic 3Doodler Start Pen playset  included enough Eco-plastic to create all or most of the 3D creations that appeared in the advertisement, which is not the case. CARU disagreed with the advertiser’s contention that it would be unreasonable for a child viewer to assume that all of the creations featured could be made with a single kit.  CARU determined that the advertiser had not adequately disclosed what was included with the initial purchase of a set.

CARU recommended that in future advertising,  the advertiser include an audio disclosure to inform children when multiple sets are depicted in a commercial.

Wobble Works, in its advertiser’s statement, said that while the company disagrees “with  CARU’s conclusions with respect to this inquiry – in particular CARU’s determination that a child viewing the commercial could reasonably believe that enough Eco-plastic came with a basic set to re-create all the finished products in the commercial – we, nonetheless, agree to comply with CARU’s recommendations in future advertising.”