flicks targeted at children
Los Angeles Times
June 5, 2008
IF YOUR kids simply
must watch the Cartoon Network, they will be overwhelmed
with ads for all kinds of tooth-rotting junk, including
Pop Tarts, Lucky Charms, Reese's Puffs and some
concoction called Froot Loops Cereal Straws. But critics
say there's a different pediatric health risk on the
cable channel -- promotions tied to violent, PG-13-rated
The ultimate financial success for almost all summer
films, especially those rated PG-13, is determined by
young ticket buyers. If school-age kids show up in
droves, you've got a blockbuster like "Iron Man" or the
new "Indiana Jones" sequel. If they stay away, you're
stuck with a misfire such as "Speed Racer." The massive
theatrical grosses for every one of last summer's top
five hits -- including "Transformers" and "Spider-Man 3"
-- were driven by kids.
In courting young fans, though, some studios -- and
their licensing partners in particular -- are becoming
so aggressive in their marketing of PG-13 titles to
children of all ages that the Federal Trade Commission,
as well as an advertising watchdog concern and one
children's advocacy organization, have all taken notice.
While studios can't sell R-rated movies directly to
young kids, they have more flexibility -- but not total
freedom -- in how they market PG-13 releases to
children, with some limitations on when certain ads can
and can't run. So instead of directly pitching the
violent movies straight to little children, the studios
are using a more subtle tactic: They let their
promotional partners do their bidding through licensed
toys and snacks.
So if your 4-year-old suddenly says he has to see "The
Incredible Hulk" -- rated PG-13 in part for "sequences
of intense action violence" and "some frightening sci-fi
images" -- it could be that he's seen a Hulk Airheads
candy spot running in the middle of the morning on
Cartoon Network's "Robotboy."
Unlike restrictions by the Cartoon Network and
Nickelodeon prohibiting Universal Pictures from directly
advertising the PG-13-rated "Hulk" before 5 p.m., there
are no apparent rules keeping Perfetti Van Melle from
flogging its Airheads confection ("Turns your tongue
green!") or Hasbro from selling its Hulk Smash Hands
(whose ad, like the Airheads spot, includes a quick clip
from the movie) in the middle of the day.
While those "Hulk" toy ads, and similar promotions for
"Indiana Jones" Legos and a toy whip, don't directly
promote the film's release date, other movie spots do.
The Campaign for a Commercial-Free Childhood found that
Burger King's "Iron Man" ads carrying the film's release
date appeared in a daytime broadcast of Nickelodeon's "SpongeBob
SquarePants," and a Paramount advertisement for "Indiana
Jones and the Kingdom of the Crystal Skull" (rated PG-13
for "adventure violence and scary images") was shown
alongside Nickelodeon's "Fairly Odd Parents" at 3:30
"Parents say, 'I thought, "How bad could [the movie] be
because they have all these toys?" ' " says Susan Linn
of the Campaign for a Commercial-Free Childhood. "And
then they take their 5-year-old to 'Iron Man,' and there
are extended scenes of torture."
Universal and Marvel Studios, which made both "Iron Man"
and the upcoming "The Incredible Hulk," declined to
comment. Paramount Vice Chairman Rob Moore said in a
statement: "Paramount has been and will continue to be
committed to advertising responsibly to children. Our
goal is to ensure parents have the information they need
to make appropriate decisions and choices for their
families. So much so, our film advertising is reviewed
by the MPAA's advertising bureau for the appropriateness
of ads and ad placements, and we carefully select our
promotional partners with whom we rely on to be equally
sensitive to parental concerns."
THERE ARE new rules controlling how R-rated movies,
explicit video games and music with racy lyrics can (and
mostly can't) be sold to children, the result of 2000
hearings in the U.S. Senate. But the directives are much
vaguer when it comes to PG-13 movies, which some parents
feel are just as violent as R-rated movies were a decade
The Children's Advertising Review Unit is an ad agency
trade group charged with industry self-regulation in
marketing aimed at kids. This March, CARU and the Motion
Picture Assn. of America entered into an agreement in
which the review unit will notify the MPAA if
advertisements for films rated PG-13, R or NC-17 are
"primarily directed to children under 12."
So far, CARU has flagged Paramount Pictures for two
possible violations, saying the studio intentionally ran
ads for "Iron Man" during unspecified children's
programming hours and did the same with "Drillbit
Taylor," a March release rated PG-13 for "crude sexual
references throughout, strong bullying, language, drug
references and partial nudity."
But the consequences of such transgressions appear
negligible and include requiring the studio to pull the
disputed ads. In the case of "Drillbit Taylor," the
organization's inquiry was filed on April 17, a month
after the ad ran and long after the film's TV campaign
was mostly wrapped up. The MPAA says it disagreed with
the group's findings and believed the "Drillbit Taylor"
and "Iron Man" ads were appropriately placed.
"The enforcement is totally lacking," says Linn. "By the
time it gets back to the MPAA, the damage is already
done. They can't preempt anything."
The FTC, on the other hand, has a lot more regulatory
clout. Even though the commission has been largely
willing to let the market police itself under President
George W. Bush, the FTC's division of advertising
practices has indicated surprising unhappiness with
Hollywood's recent conduct.
In a January letter responding to the Campaign for a
Commercial-Free Childhood's complaints about Paramount's
expansive marketing effort of the PG-13 "Transformers"
to children, FTC Associate Director Mary Engle suggested
the studios were playing fast and loose with their own
"Given [the PG-13 rating's] strong admonition to
parents, the current policy of allowing marketing of
PG-13 movies directly to a substantial number of
children under the age of 13, without express guidelines
or restrictions, could well be inconsistent with the
rating," Engle wrote in a letter sent to Campaign for a
Commercial-Free Childhood and copied to the MPAA.
Engle also noted that the current marketing efforts were
similar to earlier campaigns that the FTC considered
problematic. "Since its first report [in 2000] on the
marketing of violent entertainment to children, the
Commission has expressed concern that target marketing
of violent movies, including movies rated PG-13,
directly to children constitutes an 'end run around the
parental review role underlying the ratings.' "
The FTC's letter said that the film industry should
"assess its current approach" and consider restricting
advertising for PG-13 movies in media popular with
The MPAA has shown little public interest in taking up
the FTC's suggestions.
In a May 16 letter copied to the FTC and the National
Assn. of Theater Owners, the MPAA told the Campaign for
a Commercial-Free Childhood to stop complaining about
PG-13 movie advertising and cease its letter-writing
"The PG-13 rating is not a restrictive rating and
admission is permitted by -- and often may be
appropriate for -- children younger than 13," MPAA
general counsel Gregory Goeckner wrote, since the rating
does not prohibit anyone, no matter how young, from
buying a ticket. Advertising for PG-13 films, he said,
"is reviewed for appropriateness for the audience
expected to view the individual ad, taking into account
both the content of the ad and the content of the motion
But the MPAA says it does not review the flood of ads
for movie-related toys, candy and fast food, which are
clearly calculated to drive kiddie interest in attending
the often violent films.
So, for the time being, expect rug rats to keep asking
to see movies far more grown-up than "The Rugrats
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