BBB National Programs Archive

Crayola Participates In CARU Forum

New York, NY – Feb. 26, 2009 – The Children’s Advertising Review Unit (CARU) of the Council of Better Business Bureaus, Inc., has recommended that Crayola, LLC., a Hallmark Company, modify the disclosure in television advertising for Crayola’s “Color Explosion Glow Board” to assure children understand batteries are not included with the toy.

Advertising for the product came to the attention of CARU, the children’s advertising industry’s self-regulatory forum, through CARU’s routine monitoring of advertising directed to children. The advertising at issue aired, among other times, at 7 a.m. on the Cartoon Network during the cartoon program “Ben 10.” CARU noted in its decision that between 51 percent and 56 percent of the audience for that time period was aged 2-11 years old.

The advertiser noted at the outset that it did not intend to direct the advertisement primarily to children under 12 and indicated that the majority of ad space purchased by Crayola for this commercial was during adult programming.

CARU, however, determined that the advertising fell within its purview, given the time of day, cartoon content, and audience demographics of the program in which the advertising aired, as well as the child-directed content of programs that aired immediately before and after “Ben 10.”

CARU then examined the advertising to determine whether the disclosure regarding batteries was adequate for a child audience. The advertising at issue includes a brief, written disclosure that states “batteries not included.”

CARU noted, however, that the toy is recommended for young children, many of  whom may not be able to read or who may not understand the small print disclosure that appeared briefly at the bottom of the screen at the end of the advertisement.

Crayola, in its advertiser’s statement, said the company would take CARU’s findings into account in future advertising.

“While the advertiser does accept the decision in this case for purposes of the subject advertisement, the advertiser respectfully disagrees that an advertisement placed principally in adult media to be viewed by parents becomes advertising subject to the CARU disclosure guidelines where a small portion of placements are on children programs, though intended to be viewed by the parent demographic then watching,” the company said.