Day 050 - 10 Nov 94 - Page 33


     
     1        might interpret that in a more extreme way.  But I do not
     2        think it is the case that in other countries they would
     3        ignore the point.
     4
     5   Q.   So, for example, in that last quote that I read out,
     6        "Direct or Emotional Appeals" in the BACC guidelines ---
     7        A.  Yes.
     8
     9   Q.   -- where it says:  "Advertisements should not attempt to
    10        sell products to children by appealing to emotions such as
    11        pity, fear, loyalty self-confidence etc", that may also
    12        could include loneliness?
    13        A.  Yes.  That is not an exclusive list.  It gives examples
    14        of the kind of emotions they would object to being
    15        exploited.
    16
    17   Q.   Are you aware of any recent decision in Denmark which ruled
    18        against McDonald's advertising their food through the use
    19        of toys, on the grounds that they were really promoting
    20        toys?  Well, they were promoting food, but they were
    21        actually getting the children in on the basis of the toys
    22        and, therefore, it was deceptive?
    23        A.  No, I was not aware of that.
    24
    25   Q.   Are you aware of that kind of guideline, though, in Denmark
    26        or in other countries?
    27        A.  Certainly, in some countries, the use of premiums --
    28        which, as I explained, are part of sales promotion
    29        methods -- the use of premiums is not permitted, or limits
    30        are placed on the value of a premium, or there are other
    31        regulations.
    32
    33        The rules on sales promotion differ quite substantially
    34        from one country to another.  In this country, we have a
    35        fairly liberal interpretation on that subject.  In certain
    36        countries, they have a very tight interpretation on
    37        premiums and gifts.
    38
    39   Q.   And the advertising of them?
    40        A.  Yes.
    41
    42   Q.   What would be their reason for having those regulations?
    43        A.  Different countries have different cultural habits,
    44        traditions.  There may have been a particular case years
    45        ago which caused some problems and, therefore, they passed
    46        a rule which, in other countries, was not felt to be
    47        necessary.  There are all sorts of reasons why individual
    48        countries differ in the rules they have.  Sometimes it is
    49        protectionism.  There are many different, cultural reasons.
    50 
    51   Q.   In your experience, one of those reasons that you have 
    52        heard of for that prohibition on premiums is because it 
    53        would be felt that promoting a product through a premium
    54        could, in itself, be deceptive, especially for children?
    55        A.  I am not sure about "deceptive", but in some countries,
    56        Germany for example, they take things very literally and,
    57        therefore, the Germans tend to regard an advertisement for
    58        product X as being only about product X; it must not
    59        involve other products.
    60

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