Campaign Pushes for Product Placement Regulation

As coordinator of the coalition that submitted the letter, thank you for covering this important issue. First a correction -- the coalition is FITMedia, or Fairness and Integrity in Telecommunications Media. Among the 50 signatories are the American Academy of Pediatrics, Consumers Union, Free Press, the National Institute on Media and the Family and professionals such as Dr. Kelly Brownell, director of Yale's Rudd Center on Food Policy and Obesity. Your readers can access the letter and the full roster of signatories at FITMedia.org.

Few realize that product placement has devolved to a far more stealthy and potentially harmful practice, known as product integration. Instead of "branded props" we now have scripted dialogue, scenes and whole episodes that are doctored, or even written by advertisers behind the scenes. The goal is to inculcate targeted consumer behaviors, and the psychological scripting is both calculated and subtle.

There's nothing wrong with using a branded product as a prop in a TV show. As such, the producer does not invoke FCC rules. But when a company PAYS to hijack beloved TV characters as shills, and inputs dialogue that subtly links, for example, sugary, fatty food to emotions during a national epidemic of diabetes and obesity, people have a right to know about it -- especially parents.

Yes, adults can take care of themselves, and parents are responsible for guiding their children -- which is precisely why full disclosure is necessary. Embedded advertising is a covert practice; it enabled Kraft to advertise under the radar at a time when 1)the company had settled a dicey lawsuit on transfat in Oreo cookies and 2) junk food companies were under scrutiny for aggressively targeting children. Integrated ads have been used to promote alcohol, gambling, pharmaceuticals, dicey medical procedures and even handguns and assault weapons. And in an alarming development, TV stations are airing "fake news" segments that are produced by PR agencies with actors as "anchors."

By law, the broadcaster must disclose to the public when a message is inserted as a result of a PAYMENT. But disclosures are buried in the end credits, too small, too fleeting and too confusing ("promotional consideration provided by") to adequately inform the public. There are no disclosure rules for cable and satellite networks, and no codified rules to protect children from this covert form of marketing.

In a democracy, media integrity is a top priority. FITMedia signatories strongly support FCC rule amendments that will improve transparency by specifying the size, placement and duration of Sponsorship Identification disclosures, extend disclosure rules to cable and satellite, and ban the practice in programs for children under 12. These are not excessive regulations, but fair and necessary rules of the road.

N. E. Marsden of CA 5:58PM October 27, 2009