Diageo halts all Snapchat advertising after watchdog says Captain Morgan lens appealed to kids
Diageo says the lens used age-gated targeting to ensure it was only delivered to users with a registered age of 18+ years, and that the cartoon did not use bright colors that would appeal to children.
However, the Advertising Standards Authority (ASA) ruled that the cartoon pirate was of particular appeal to under 18s, and that - on a platform popular with under 18s - Diageo had not taken enough care to ensure its ad was correctly targeted.
Children’s cartoon or historical representation?
The Snapchat lens, used to advertise the Captain Morgan rum brand in June 2017, included a cartoon icon of a pirate. The lens made the user’s face look like Captain Morgan, while featuring two glasses of a mixed alcoholic drink clinking together on screen. A seagull flew a scroll on the screen which said ‘Live like the Captain’, and a voice-over said ‘Captain’ with the sound of people cheering.
The ASA challenged the lens on two counts - whether it was of particular appeal to U18s, and whether it was directed at people U18 - and ruled that the lens breached the advertising code on both points.
Diageo said the Snapchat lens image of Captain Morgan was consistent with its brand trade mark and packaging, which depicts a historical buccaneer in traditional 17th century attire, while the scroll and tankards fit in with the era.
However, the ASA considered the lens icon in the Snapchat user’s carousel was a cartoon pirate with a ‘bright, child-like image’. “In that context, we considered that the icon image of a cartoon pirate was of particular appeal to under 18s,” it said in its ruling.
While the lens itself was not deemed to use particularly bright colors, the ASA said the “comedic effect’ of the lens, along other aspects, “was likely to appeal particularly to those under 18”.
Who was the ad targeted at?
Captain Morgan added that the lens used age-gated targeting to ensure it was only delivered to users aged 18+. Snap Inc added that alcohol advertising in the UK is only directed at users who enter a date of birth to show they are over 18.
But the ASA questioned the effectiveness of Snapchat’s audience targeting, pointing out that supplied ages were unverified. Drawing on research from Ofcom, it called into question “the adequacy of self-reported age as the sole means of targeting alcohol advertising on Snapchat”.
CAP advertising code
18.14: Marketing communications must not be likely to appeal particularly to people under 18, especially by reflecting or being associated with youth culture. They should not feature or portray real or fictitious characters who are likely to appeal particularly to people under 18 in a way that might encourage the young to drink. People shown drinking or playing a significant role should not be shown behaving in an adolescent or juvenile manner.
18.15: Marketing communications must not be directed at people under 18 through the selection of media or the context in which they appear. No medium should be used to advertise alcoholic drinks if more than 25% of its audience is under 18 years of age.
At the time the lens was offered, Snap Ltd was only able to target lenses by self-reported age and geolocation (this has since been extended to target ads using interest-based factors).
Captain Morgan says it ensures all marketing communications on social media only appear where a minimum of 75% of the audience are 18+, in line with the advertising code. It added that information provided by Snap Inc showed that, in 2016, 77% of UK Snapchat users were registered as 18+.
But the ASA found that “a significant minority of UK based Snapchat users were registered as being between 13 and 17 years old and represented one of the largest groups of their total UK audience.”
In an Ofcom 2017 survey of 343 teenagers aged 12-15 years old who had social media accounts, 58% of them had a Snapchat account, leading the ASA to conclude Snapchat is popular among younger audiences.
The ASA concluded the lens must not appear again in its current form. It also told Captain Morgan to ensure its ads were appropriately targeted in the future and were not of particular appeal to under 18s.
In response to the ruling, a Diageo spokesperson said: “We have a strict marketing code, take our role as a responsible marketer very seriously and acknowledge the ASA’s ruling. We took all reasonable steps to ensure the content we put on Snapchat was not directed at under 18s - using the data provided to us by Snapchat and applying an age filter.
“We have now stopped all advertising on Snapchat globally whilst we assess the incremental age verification safeguards that Snapchat are implementing.”
Alcohol advertising and children - what is and isn't acceptable?
Last month regulators pulled up Tiny Rebel Brewing Company for inadvertently creating cans that were deemed to appeal to U18s.
The Portman Group, a self-regulating body for the alcohol industry, said the brewery's Cwtch Welsh Red Ale cans could appeal to children through graffiti style graphics, bold colors and the use of the 330ml can that can be associated with soft drinks.
Tiny Rebel has since changed its cans but pointed out the 'enormously subjective' interpretation of what is and isn't acceptable.
