Six Key Changes in CARU's Revised Advertising Guidelines

Advertisers should be aware that child-directed marketing and advertising will be reviewed under revised self-regulatory guidelines, to go into effect on January 1, 2022. BBB National Programs Children’s Advertising Review Unit (CARU) last week issued a revised version of the CARU Advertising Guidelines, widely recognized industry standards that ensure advertising directed to children is not deceptive, unfair, or inappropriate for its intended audience. These Guidelines were revised to address newer digital and immersive forms of child-directed interactive media more specifically. 

CARU’s self-regulatory role is to review and evaluate advertising, whether in print or digital ads, on TV, on product labeling, or now, within games and apps, for truth, accuracy, appropriateness, and sensitivity to the uniquely impressionable child audience. The revised Guidelines extend this watchful eye to now include video, influencer marketing, apps, in-game advertising, and purchase options in games. 

Starting January 1, 2022, CARU will begin reviewing the marketplace for non-compliance with the revised Guidelines. Until that time, CARU will continue to review and evaluate advertising under the current Guidelines. 

To help advertisers prepare for the debut of the new Guidelines, we have highlighted six key changes: 

From concept to final cut, CARU’s pre-screening services help businesses and agencies spot and correct problems before ads go live.  Learn more.

1. Children: Under Age 13

The revised Guidelines now cover advertising primarily directed to children under age 13 in any media. The current Guidelines covered advertising directed to children under age 12. This change aligns with COPPA, the Children’s Online Privacy Protection Act, which provides protections against the online collection of personal information from children under age 13. 

At the same time, the revised Guidelines recognize that, for instance, advertising aimed at children 10-12 years old should not have to look or sound like advertising directed to 5-year-olds. New language in the Guidelines makes clear that determining whether advertising complies with the Guidelines will be based upon the age-range of the target audience.  

2. Diversity and Inclusion

CARU’s revised Guidelines take a stand on the need for advertising in the children’s space to promote positive change by reflecting the diversity of humanity and providing an inclusive space where children of all races, religions, cultures, genders, sexual orientations, and physical and cognitive abilities can feel valued and respected. Building upon the positive strides made by many advertisers, the Guidelines make clear that advertising portraying or encouraging negative social stereotyping, prejudice, or discrimination violates CARU’s standards. 

3. In-App and In-Game Advertising and Purchases

Recognizing that kids spend considerable free time playing games on their mobile devices, the revised Guidelines specifically call out the use of unfair, deceptive, or other manipulative in-app and in-game advertising and purchase offer tactics. 

The Guidelines identify examples of violative practices, such as the use of deceptive door openers and social pressure or validation to mislead or cause children to unknowingly or inadvertently engage in ad viewing or make in-app purchases. CARU’s guidelines make clear that advertisers, app designers, and developers must create these spaces with children in mind and build in transparency from the start.

4. Endorsers and Influencers

CARU recognizes the tremendous popularity and impact that endorsers and influencers have in the child’s space. When it comes to influencer marketing, the Guidelines say to make it clear and obvious - in language children can easily understand - that an influencer is being paid or receiving free product to promote or play with an advertiser’s products or services. 

5. Blurring

CARU and most advertisers recognize that children have limited knowledge, experience, sophistication, and maturity to evaluate the credibility of information and may not even understand when they are viewing or hearing advertising. While the blurring of advertising and non-advertising content isn’t new, the power of children’s digital media to blur these lines means it is especially important for advertisers to clearly and conspicuously inform children that what they are seeing is advertising – in simple language that they can understand. The Guidelines make clear that transparency is key.

6. Material Disclosures

The exploding range of digital media directed to children, including influencer marketing, games, and other immersive content, heightens the need for and importance of clear and conspicuous disclosures of material information in words that children can understand.  

The Guidelines have been revised to better spell out what clear and conspicuous mean in the context of different advertising formats. For instance, the Guidelines make clear that, with limited exceptions, in audio-video advertisements, disclosures should be made in both audio and video form to best ensure that children see/hear them. In addition, in videos and other content that lasts more than a few minutes, advertisers must repeat this disclosure more than once so that children are more likely to get the message.

Ongoing Evolution and Support

Over the years, the CARU Advertising Guidelines have been revised periodically to address changes in media and marketing. Moving forward, as new challenges and questions about application of the Guidelines arise, the CARU Advertising Guidelines will be updated through FAQs. These updates will be posted to the bbbprograms.org website and the CARU team will communicate those changes through vehicles such as this blog, which breaks down what you need to know.

Here are some other education and support options for advertisers getting familiar with the new Guidelines:

• For in-depth training on the new revisions to the Guidelines, industry professionals should register for Kidvertising, a half-day training scheduled for October 13, 2021. The CARU team will walk attendees through the changes, provide examples of real-world applications, and answer attendee’s questions about what this might mean for campaigns in progress. 
• BBB National Programs offers advertising pre-screening services to help companies, agencies, and developers spot and correct problems before child-directed advertisements and promotional content (e.g. websites) go live.