The Campaign For a Commercial-Free Childhood has asked the Federal Trade Commission to step in to stop the film industry from advertising violent PG-13 films in broadcast and cable TV shows aimed at young kids. The industry counters via the MPAA that it has been complying with self-regulatory standards to steer those adds to appropriate time periods and programs.
In a letter dated Aug. 5 to FTC Chairman Jon Leibowitz, CCFC said the Motion Picture Association of America (MPAA) "Has not come up with an explicit policy and criteria" to ensure that "PG-13 movies are not marketed in a manner inconsistent with their rating," which it points out was the recommendation of FTC staffers to the industry in 2007 in response to a CCFC complaint 16 months ago.
CCFC sent the letter in advance of the Aug. 7 premiere of Hasbro's GI Joe: The Rise of the Cobra, saying that was "the culmination of a summer-long barrage of marketing for violent blockbusters targeting children." It says over 3,000 members signed the FTC petition.
CCFC is also concerned about ads for X-Men, Wolverine, Star Trek, Terminator, and Transformers, saying ads for those and G.I. Joe aired during hours when young kids were likely to be watching.
"None of the movies that they have identified as being problematic have ever been approved for placement before 5 p.m.," said MPAA spokeswoman Angela Martinez, "and are only placed with compatible programming at times when parents are more likely to be aware of their children's viewing habits."
"The MPAA Advertising Administration takes seriously its role of ensuring that ads that run during children's programming are appropriately placed," she said.
The MPAA has its own ad-screening arm. Studios that submit their movies for ratings to the MPAA's Classification and Ratings Administration must also submit their ads to the Motion Picture Advertising Administration to make sure they are suitable for the target audiences, particularly kids, and according to a set of guidelines.
She said some ads for PG-13 movies are not allowed to air in children's television programming at all. "Those that are approved we believe are appropriate based on the specific content of the motion picture and of the ad itself. Unfortunately, the CCFC continues to cite inaccurate data about the advertising that has been approved during regular children's viewing hours."
CCFC has some company in its criticism of advertising PG-13 films in kids TV shows.
The Council of Better Business Bureau's Children's Advertising Review Unit (CARU) has referred a host of film ads to MPAA in that 16-month period for a decision on whether those ads should have been advertised in kids TV shows.
Those include spots for Harry Potter, Pirates of the Caribbean, X-Men, Iron Man, Spiderman, Hulk, The Mummy, Star Trek and many more. CARU began referring the ads to MPAA per an agreement struck in March 2008 after the two parties could not agree on whether PG-13 ads should air in kids' shows.
According to MPAA, it has vetted all the CARU referrals and in all cases felt the ad placement squared with its guidelines, except in a couple of cases where the TV station aired the ad in other-than-approved slots or shows. In each case they have explained the decision to CARU, said Martinez.
CARU's stand has been that PG-13 films should not be advertising in shows targeted to young kids because the rating means that some of the content may not be appropriate for them. MPAA has countered that there should be no line drawn in the sand because "PG-13 does not necessarily mean you can't take a younger child to it."
That was the response of ratings board head Joan Graves to a question from B&C on the subject following a speech last fall. She pointed out that the ratings contain content descriptors that help parents decide which of those movies might be suitable for their kids-say a film with course language might be ok with some parents, but not one with sexuality. "Many 13's are appropriate for younger children," she added.
Martinez echoed that point: "It is important to note that the PG-13 rating does not mean that all PG-13 films are inappropriate for children under 13. It is simply an indication that the level of content is stronger than a PG but doesn't reach a level requiring an R. The PG-13 rating entrusts the decision of what content is appropriate for children to their parents taking into account the individual maturity and sensitivities of each child."
A source familiar with MPAA's ad-screening philosophy said the industry argues that a case-by-case, subjective approach can be more restrictive than a "bright-line" approach. "If you simply have bright lines, you are going to have a lot more advertising that goes to audiences that are inappropriate."
The source said that the "vast majority" of PG-13 movies are not approved for advertising in children's shows, and that the movie industry has outlined its kids ad philosophy to the FTC.
The CCFC petition also comes only weeks before the FCC is scheduled to report on content-control technology to Congress. One proposal has been to put ratings on commercials themselves so that a V-chip/ratings system would be able to screen them out.