For Brands and Influencers: Get to Know the CARU Advertising Guidelines

Sep 23, 2021, 09:00 AM by Rashida Gordon, Analyst, Children’s Advertising Review Unit

Today, endorsers who promote products and services on social media are commonly known as influencers. And in the past several years, one of the most noticeable changes to the children’s advertising landscape has been the meteoric rise of influencer marketing.

The Children’s Advertising Review Unit (CARU) of BBB National Programs recently revised our CARU Advertising Guidelines to specifically address endorser marketing and other advertising formats now ubiquitous on social media platforms. The CARU Advertising Guidelines are widely recognized industry standards that help ensure advertising directed to children is truthful, fair, and not inappropriate for its intended audience across any form of child-directed media. 

Children can access on a variety of platforms and devices almost limitless online content featuring individuals playing with toys or games, eating popular foods, or engaging in other activities involving children’s brands. Some of this content is organic – individuals sharing their real-life experiences and unbiased opinions – and some is advertising – influencers who are paid or receive free product or other benefits to promote an advertiser’s brand. 

It can be difficult, or even impossible, for children to know the difference between the two. That’s why it’s essential to disclose to children – in language they can understand – when an influencer is advertising the featured product. 

If you have a role in influencer marketing to children, here are some key revisions to the CARU Guidelines that you should know. 


Disclose Your Material Connections 

The revised CARU Guidelines make clear that both advertisers and their influencers are responsible for ensuring that influencers who promote the advertiser’s brands clearly and conspicuously disclose their material connection to that advertiser.  

A material connection means that there is a financial, employment, personal, or family relationship between the advertiser, i.e., the company or brand, and the influencer. For example, if a child influencer posts videos reviewing toys she received for free from a toy brand, or the brand paid her to feature its toys in her videos, that is a material connection that must be disclosed in each of the influencer’s posts or videos where the toy brand appears. 

The CARU Guidelines provide that influencers’ disclosures should be clear, in simple words that children can understand, such as “This is an advertisement for XYZ toys.” These disclosures also need to be conspicuous; in videos, for instance, disclosures made in both audio and video are likely to be most effective. 

Of course, if an influencer has no relationship with a brand, and is just telling viewers about a product they happen to like, there is no need for a disclosure. 


Don’t Over-Promise with Ad Claims 

Advertisers frequently look to their influencers for original and creative ways to tout their brands to children and entice their interest. CARU’s Guidelines remind advertisers and influencers that claims made by influencers are part of the advertisement and they should not embellish beyond what the product can deliver. In other words, advertisers and their influencers share responsibility for making sure the claims don’t require proof the advertiser does not have. 

For example, if an influencer endorses a math games app for children, claiming the app helped his class score 10% higher on their math tests, the advertiser must first have proof to back up this claim. Similarly, if an influencer for a granola bar brand claims the snacks have 15% more protein than other leading brands, but in actuality they have only 3% more, neither the advertiser nor the influencer are in compliance with CARU’s Guidelines. 


Reflect Actual Beliefs and Experiences 

The Guidelines also state that advertisers should recognize that the mere appearance of a celebrity or influencer can significantly alter a child’s perception of a product or service. 

If children build a parasocial relationship with a popular character or personality, meaning they unrealistically see that character or person as a trusted friend, the character’s endorsement of a product could have a substantial influence on the importance the child places on the claims made. This parasocial effect is another reason why celebrities and influencers with child audiences should not falsely imply that using a product or service enhanced their performance; nor should they make endorsements for products that don’t reflect their actual experiences and beliefs. 

For example, what if an influencer with a large child audience endorses a sneakers brand that he does not actually wear. Or, if a popular celebrity says she loves a product when she really thought it was terrible. Both influencer ads could violate CARU’s Advertising Guidelines.


Get to Know the Rules of the Road

If your company uses influencers in your advertising, or if you are an influencer yourself, get to know the Guidelines. You can read the revised CARU Advertising Guidelines in full here. Still have questions? CARU is hosting its second annual Kidvertising event this October, a half-day workshop to provide hands-on education about the revised Guidelines before they go into effect on January 1, 2022. Find out more and register here.  

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