Today, the Federal Trade Commission issued an important report, Marketing Violent Entertainment to Children:  A Sixth Follow-Up Review of Industry Practices in the Motion Picture, Music Recording & Electronic Game Industries.  At the urging of the Campaign for a Commercial-Free Childhood (CCFC), this year’s review included a thorough examination of the marketing of violent PG-13 films to young children.  For the past three years, CCFC has documented how blockbuster violent PG-13 movies are blatantly marketed to young children and urged the Motion Picture Association of America to put an end to this practice.   

Below is the statement of CCFC’s Dr. Susan Linn on the report:

The FTC’s report is must-read for anyone concerned about the marketing of violent media to children.  The report demonstrates that, when it comes to protecting young children from marketing for violent PG-13 movies, industry self-regulation has been a complete failure. The MPAA continues to turn a blind eye toward studios making an end run around parents in order to target children directly with violent content.

The FTC’s review of ad placements confirms CCFC’s findings that the targeting young children for violent PG-13 films is pervasive.  PG-13 movies were regularly advertised on children’s networks such as Nickelodeon and the Cartoon Network, even though 2- to 11-year-olds comprise 50% of viewers on these stations regardless of time of day. The FTC’s review of studio marketing plans demonstrates that violent PG-13 movies are deliberately targeted to young children, even when studios are aware that parents object to this practice. In one shocking example, when market research found that many parents of children ages 7 to 12 were concerned that a movie was too violent, the studio did not alter its plan to market the film to young children.  Instead, the studio changed its advertisements to deemphasize the violent content to “convince more parents that [this movie] will be ‘safe for their kids to see.'”  Another film was heavily promoted to young children through tie-ins with foods and toys, even though the studio’s market research found that many parents considered the film too disturbing for their children.  

We are pleased that FTC questions the effectiveness of the film industry’s self-regulatory efforts.  The report dismisses the MPAA’s much-hyped referral agreement with the Children’s Advertising Review Unit  – an agreement the MPAA claimed would address concerns about PG-13 marketing – as “not a meaningful self-regulatory measure.”  The report also notes that the MPAA does not consider movie cross-promotions or other marketing tie-ins to be within its purview, despite the fact these techniques are often part of a deliberate strategy to target younger children.   In one instance, the FTC found that the target demographic for licensed products for a violent PG-13 film was boys 3 to 11.

While the FTC does an admirable job of documenting the problem, the Commission’s proposed solution – that the MPAA develop an explicit policy for the marketing of PG-13 to young children – is too little, too late.  For years, parents, advocates for children, and even the FTC’s staff, have asked the MPAA to develop such a policy, but the MPAA seems far more concerned with protecting film industry profits than protecting the wellbeing of children.  Since the MPAA is unwilling to enforce marketing standards based its own rating system, the FTC should develop its own set of rules.  If there is any question whether the Commission has that authority, then Congress should explicitly empower the FTC with full rulemaking authority to protect children from harmful advertising.

The FTC’s report is available at http://ftc.gov/opa/2009/12/violentent.shtm.

The Campaign for a Commercial-Free Childhood is a national coalition of health care professionals, educators, advocacy groups and concerned parents who counter the harmful effects of marketing to children through action, advocacy, education, research, and collaboration. CCFC is headquartered at the Judge Baker Children’s Center in Boston.  www.commercialfreechildhood.org/.