Tag: Reportedtimes

New York, NY – May 29, 2024 – In a challenge brought by The Procter & Gamble Company (P&G), BBB National Programs’ National Advertising Division recommended that Reckitt Benckiser LLC modify or discontinue certain claims for its Finish Powerball Ultimate Dishwasher Tablets.

Finish Ultimate includes Reckitt’s patent-pending CycleSync technology that uses a delayed-release coating system to separate the dosage time between the bleaching and enzyme systems such that dish stain removal is improved. The challenged advertising campaign touted it delivers the “Ultimate Clean” and is “Engineered for the Ultimate Clean in the Toughest Conditions.”

The challenged claims appeared in Finish Ultimate and third-party webpages and commercials.

In its decision, the National Advertising Division (NAD) determined that “Ultimate Clean,” depending on the context, could convey one of the following messages, each requiring different evidence for substantiation:

• The self-referential superiority claim that Finish Ultimate cleans the best among Finish Products;
• The market superiority claim that Finish Ultimate cleans better than all other detergents (sometimes limited to the toughest conditions); and
• The monadic performance claim that Finish Ultimate is able to deliver excellent cleaning results in the toughest conditions (sometimes up to and including the toughest conditions) as depicted by before-and-after demonstrations.

While NAD determined that some challenged advertisements convey the message that Finish Ultimate cleans the best among Finish products, this was not a claim challenged in this proceeding.

Market Superiority Claims

The National Advertising Division (NAD) has found that the best way to establish the comparative or superior performance of a sensory attribute (i.e., consumer perception of cleanness) is through head-to-head product testing. As Reckitt did not provide head-to-head testing or argue the testing it did provide would show that Finish Ultimate is superior to the market, NAD recommended that Reckitt modify its advertising to avoid conveying the message that Finish Ultimate is superior to all other detergents.

Monadic Performance Claims

NAD recommended that Reckitt discontinue its advertisements that tie “Ultimate Clean” expressly to “the toughest conditions” that depict burnt-on stains that are dramatically tougher than those tested or describe conditions that were tougher than its testing could support. Or alternatively, to modify its advertising to more closely reflect the results supported by its testing.

In its advertiser statement, Reckitt stated that it will comply with NAD’s recommendations even though it “respectfully disagrees with NAD’s interpretation of some of the advertising at issue.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. This press release shall not be used for advertising or promotional purposes.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About the National Advertising Division: The National Advertising Division of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. The National Advertising Division reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.

Contact Information:
Name: Jennie Rosenberg
Email: jrosenberg@bbbnp.org
Job Title: Media Relations

New York, NY – May 23, 2024 – A panel of the National Advertising Review Board (NARB), the appellate advertising body of BBB National Programs, determined (one panelist dissenting) that The Glad Products Company’s “25% more durable” claim for Glad ForceFlex MaxStrength bags, as it appears on the packaging of 45- 34- and 20-bag sizes, is not misleading.

In the underlying National Advertising Division (NAD) challenge (Case No. 7309), Reynolds Consumer Products LLC argued that because Glad’s disclosures concerning the nature of the comparison were not clear and conspicuous, the “25% more durable” claim misleads consumers into interpreting the message as a claim of superiority compared to competing brands of tall kitchen bags.

NAD recommended that Glad modify the claim to include clear and conspicuous disclosures indicating the object of comparison is Glad’s own 13-gallon ForceFlex bags. Glad accepted the decision for its search ads and website, however, appealed NAD’s recommendation that it modify its “25% more durable claim” on certain packaging.

Regarding the Glad ForceFlex MaxStrength packaging, the NARB panel majority came to a different conclusion from NAD. Two of the three panelists found that, in the context of the three packaging samples provided to the panelists (45- 34 and 20-bag sizes), Glad’s “25% more durable” claim is not misleading. All three panelists agreed that its conclusions are limited to the examined packaging and are not a comment on the more durable claim as it may be presented in other forms of advertising.

Glad stated that it is “very pleased with NARB’s conclusion that its ‘25% More Durable*’ claim is not misleading as presented on its product packaging.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About the National Advertising Review Board (NARB): The National Advertising Review Board (NARB) is the appellate body for BBB National Programs’ advertising self-regulatory programs. NARB’s panel members include 85 distinguished volunteer professionals from the national advertising industry, agencies, and public members, such as academics and former members of the public sector. NARB serves as a layer of independent industry peer review that helps engender trust and compliance in NAD, CARU, and DSSRC matters.

Contact:
Jennie Rosenberg
Media Relations
BBB National Programs
press@bbbnp.org

New York, NY – May 16, 2024 – In a challenge brought by The Glad Products Company, BBB National Programs’ National Advertising Division determined that HoldOn Bags Inc. has a reasonable basis to claim that its trash bags break down in compost environments.

However, the National Advertising Division (NAD) recommended that other challenged claims either be discontinued or modified to:

• Clearly and conspicuously disclose the circumstances in which the bag would degrade, compost, or “break down.”
• Avoid conveying messages of general environmental benefits.
• Avoid conveying the message that HoldOn bags are not plastic.

HoldOn is a provider of trash bags certified by the Biodegradable Products Institute, Inc. (BPI) and TÜV Austria as compostable in commercial and home composting settings.

In support of its claims that HoldOn bags break down in compost facilities, the advertiser presented evidence through an expert in the field of compostable plastics and certifications from BPI and TÜV Austria that indicated the bag’s suitability for composting in both commercial and home composting environments.

NAD found that the evidence provided a reasonable basis for HoldOn to make claims that its bags break down in composting environments but did not support claims that the bags would break down in non-composting environments, such as landfills. NAD also found that the evidence was insufficient to support claims of general environmental benefits. NAD recommended that HoldOn’s claims conveying messages of environmental benefits be discontinued or modified to be limited to the bag’s ability to degrade in composting environments.

NAD also found that some HoldOn advertisements conveyed messages that its bags are not plastic, however, no evidence in the record supported that message. NAD recommended HoldOn discontinue or modify its claims to avoid conveying the message that its bags are not plastic.

In its advertiser statement, HoldOn stated that it will comply with NAD’s decision although it disagrees with certain aspects of it.

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. This press release shall not be used for advertising or promotional purposes.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About the National Advertising Division: The National Advertising Division of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. The National Advertising Division reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.

Contact:
Jennie Rosenberg
Media Relations
BBB National Programs
press@bbbnp.org

New York, NY – May 15, 2024 – Following a BBB National Programs’ National Advertising Division challenge brought by competitor Vesync Corporation, Antadi LLC d/b/a Aroeve Direct voluntarily discontinued certain claims for its HEPA air purifiers.

Vesync challenged claims that certain models of Aroeve’s air purifiers and replacement filters are compliant with HEPA and/or H13 standards and that they are listed at a discounted “bargain” price.

In response to the challenge, Aroeve stated that it would permanently discontinue the challenged claims for business reasons unrelated to this challenge.

Aroeve informed the National Advertising Division (NAD) that prior to the challenge it had begun an internal review of its third-party testing and consumer sales data as part of an ongoing periodic refresh of its marketing materials. Aroeve represented that no new advertising claims similar to the challenged claims are being introduced to the marketplace and confirmed that existing claims similar to the challenged claims are in the process of being removed.

Therefore, NAD did not review the claims on their merits and will treat the claims, for compliance purposes, as though NAD recommended they be discontinued.

In its advertiser statement, Aroeve stated it agrees to comply with NAD’s recommendations and appreciates the opportunity to participate in the self-regulatory process.

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. This press release shall not be used for advertising or promotional purposes.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About the National Advertising Division: The National Advertising Division (NAD) of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. NAD reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.  

 

Contact Information:
Name: Jennie Rosenberg
Email: jrosenberg@bbbnp.org
Job Title: Media Relations

New York, NY – May 9, 2024 – BBB National Programs’ National Advertising Division recommended, as part of its routine monitoring program, that Amyris Clean Beauty, Inc. modify the claim “Clinically-proven to quickly and visibly lift, firm and diminish the appearance of fine lines for a revitalized eye area” to reflect that the “quick” and “visible” results relate only to hydration and “the appearance of fine lines.”

The National Advertising Division (NAD) also recommended that actress Reese Witherspoon’s status as a Biossance brand ambassador be clearly and conspicuously disclosed. NAD’s inquiry further focused on whether the format of the challenged advertising gives the impression of editorial content from InStyle and Hello! Magazines and Sephora.com when, in fact, they are advertisements.

“Clinically-Proven” Claim

As support for its claim “Clinically-proven to quickly and visibly lift, firm and diminish the appearance of fine lines for a revitalized eye area,” Amyris relied on a clinical study that included instrumental measurements of skin hydration and elasticity, digital photographs, and participant questionnaires.

After reviewing the evidence, the National Advertising Division (NAD) determined the subjective portion of the questionnaire used in Amyris’ study could not support the portion of the “clinically-proven” claim that the product can “quickly and visibly” lift and firm and recommended that portion of the claim be discontinued. However, NAD found that other portions of the claim were supported, therefore recommended the claim be modified to reflect that the “quick” and “visible” results pertain only to hydration and “the appearance of fine lines.”

Clarifying Reese Witherspoon’s Ambassador Status, NAD noted that content featuring product claims and a paid endorsement such as, “This Reese Witherspoon-Approved Eye Cream Hydrates and Brightens,” should clearly and conspicuously disclose the material connection to the brand.

Editorial/Advertising Line Blurring

The National Advertising Division (NAD) noted the importance of providing consumers with disclosures about economic relationships between social media, online publications, digital publishers, and brands or products so consumers can distinguish ads from editorial content. When content is created due to affiliate relationships between a brand and digital publisher, the content is promotional and is advertising.

NAD cautioned Amyris to evaluate its business relationships with publishers and determine whether the content is advertising or editorial and, to the extent it is the former, that the claims are fully supported.

“#1 Best-Selling Eye Cream at Sephora”

During the proceeding, Amyris’ “#1 Best-Selling eye cream at Sephora” claim was permanently discontinued. The National Advertising Division (NAD) noted that it will treat the permanently discontinued claim, for compliance purposes, as though NAD recommended its discontinuance and the advertiser agreed to comply.

In its advertiser statement, Biossance stated that it “will comply with NAD’s recommendations” although it disagrees with certain aspects of the decision.

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. This press release shall not be used for advertising or promotional purposes.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About the National Advertising Division: The National Advertising Division of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. The National Advertising Division reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.

Contact Information:
Name: Jennie Rosenberg
Email: jrosenberg@bbbnp.org
Job Title: Media Relations

New York, NY – May 8, 2024 – In a challenge brought by The Procter & Gamble Company (P&G), BBB National Programs’ National Advertising Division recommended that Unilever United States, Inc., in connection with its Degree Advanced Antiperspirant:

• Discontinue express and implied claims that Degree Advanced completely prevents underarm sweat and sweat marks during intense exercise sessions.
• Modify its “Samuel” commercial to avoid conveying the message that all Degree Advanced antiperspirant products provide superior wetness prevention and reduction compared to all Old Spice antiperspirant products.
• Discontinue side-by-side demonstrations of visible sweat marks on Old Spice underarms and the dry underarms of Degree Advanced users.

The challenged advertising was part of Unilever’s “Gray T-Shirt Challenge” campaign, which featured individuals applying Degree Advanced 72-hour antiperspirant products in social media and TV ads while wearing a gray t-shirt, notorious for showing sweat. After “their sweatiest” workout, the videos and commercials depict the user’s completely dry underarms.

Gray T-Shirt Challenge Claims

In its decision, the National Advertising Division (NAD) determined that Unilever’s social media videos and commercials in context convey a message that Degree Advanced antiperspirant completely prevents underarm sweat and sweat marks throughout intense exercise.

In support of its claims, Unilever relied on the results of hot room and SweatSENSE studies. NAD found that while the evidence in the record demonstrates Degree Advanced antiperspirant’s extra effectiveness at reducing underarm sweat, the product demonstrations in the videos and commercials go beyond sweat reduction and show the absence of sweat marks on users’ underarms.

NAD concluded that Unilever’s evidence was not a good fit to support the challenged claims and recommended that Unilever discontinue the express claims:

• “moving for hours. Still dry,”
• “no sweat marks,”
• “while your workout will leave your gray t-shirt soaked, Degree will protect those pits at all costs,”
• “I am sweating but nothing on my armpits,”
• “Degree deodorant, 72-hour protection and you don’t even see [any] gray armpit stain,”
• “after a great workout, we have no sweat stains” and
• “even when sweat builds up on your chest or back, Degree Advanced keeps your underarms dry and odor at bay.”

NAD also recommended that Unilever modify its advertising to avoid conveying the unsupported message that the full line of Degree Advanced antiperspirants completely prevent underarm sweat and sweat marks during intense exercise. NAD noted that nothing in its decision prevents Unilever from making other claims that are accurate and narrowly tailored to the results of Degree Advanced’s hot room and SweatSENSE studies.

“Samuel” Commercial Clams

NAD found that Unilever’s “Samuel” commercial communicates a comparison between the Degree Advanced line of antiperspirants and the Old Spice line of antiperspirants. 

NAD found that the depiction of Samuel completing several rounds of pull-ups and then showing his results of a dry underarm with Degree Advanced and a wet underarm with Old Spice conveyed the implied message that users of the full line of Old Spice antiperspirants will experience visible underarm sweat marks during intense exercise before Degree Advanced users will experience any visible underarm sweat marks.

Having determined that Unilever’s studies are not a good fit for claims regarding visible sweat marks on a t-shirt, NAD recommended that it be discontinued.

Further, NAD determined that the Samuel commercial conveys the implied message that the full line of Degree Advanced antiperspirants provides superior wetness prevention and reduction compared to the full line of Old Spice antiperspirants. Because the record did not contain testing on Degree Advanced sticks and Old Spice sticks, NAD recommended that Unilever modify its advertisement to avoid conveying such a message.

In its advertiser statement, Unilever stated that it will comply with NAD’s recommendations even though it “respectfully disagrees with NAD’s interpretation of the claims at issue.”

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. This press release shall not be used for advertising or promotional purposes.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About the National Advertising Division: The National Advertising Division of BBB National Programs provides independent self-regulation and dispute resolution services, guiding the truthfulness of advertising across the U.S. The National Advertising Division reviews national advertising in all media and its decisions set consistent standards for advertising truth and accuracy, delivering meaningful protection to consumers and leveling the playing field for business.

Contact Information:
Name: Jennie Rosenberg
Email: jrosenberg@bbbnp.org
Job Title: Media Relations

• Long-awaited successor to iconic KO2 tire hits the market
• Phased launch begins with 13 replacement sizes this month
• KO3 tire performance improves upon that of the KO2 tire

 

GREENVILLE, S.C., May 1, 2024 – BFGoodrich Tires invented and revolutionized the all-terrain tire. Now it’s doing it again with the BFGoodrich All-Terrain T/A KO3 tire.

Building on the outstanding performance of the BFGoodrich All-Terrain T/A KO2 tire, BFGoodrich developed the KO3 tire to satisfy the evolving needs of off-road consumers by incorporating the latest tire technologies into a tire that delivers even stronger performance and benefits than the KO2 tire.

“BFGoodrich Tires’ legendary toughness has been made tougher with the creation of the All-Terrain KO3 tire,” said Harold Phillips, BFGoodrich Global General Manager. “We’ve done a lot of racing and research in the 10 years since we launched the KO2 tire, so a decade of data, feedback, technology and experience went into the development of the KO3 tire. We are our own competition, and we knew it was time to take the all-terrain tire to another level. It will be exciting to see what consumers will do – at work and at play – with the KO3 tire.”

BFGoodrich will introduce more than 100 sizes over 24 months, starting with 13 sizes available in May. The phased launch will continue with 17 additional sizes in August and five more sizes in October. An additional 52 sizes arrive in 2025 and 19 sizes in 2026.

The All-Terrain T/A KO3 tire has improved wear performance, improved gravel road durability, and improved snow traction while maintaining the sidewall toughness and soft soil traction of the KO2 tire.

Treadwear: BFGoodrich engineered the All-Terrain T/A KO3 tire with a new tread pattern and new all-terrain tread compound to provide durability and longevity, even on gravel. The KO3 tire has an optimized footprint and full-depth 3D locking sipes designed for even wear over the long haul.

Toughness: CoreGard Technology gives the KO3 tire excellent sidewall toughness, which earned it the Baja Champion badge. The Advanced Deflection Design helps prevent objects from snagging and splitting the sidewall.

Traction: Even in the worst conditions, the All-Terrain T/A KO3 tire is made to grip. The serrated shoulder design and Mud-Phobic Bars improve upon the KO2 tire’s outstanding mud and snow traction, helping it earn the Three-Peak Mountain Snowflake severe-snow rating.

These features have been proven to provide the following benefits:

• The BFGoodrich All-Terrain T/A KO3 tire has better wear performance than the BFGoodrich All-Terrain T/A KO2 tire.
• The All-Terrain KO3 tire’s new tread pattern design and new all-terrain tread compound provide better gravel road durability than the All-Terrain T/A KO2 tire. 
• The All-Terrain KO3 tire’s new tread pattern design and new all-terrain tread compound provide better snow traction than the All-Terrain T/A KO2 tire.

The All-Terrain T/A KO3 tire is the newest member of the Terrain Family of BFGoodrich tires. The KO3 tire carries a 50,000-mile warranty and 60-day satisfaction guarantee. For more information, visit bfgoodrichtires.com or your local BFGoodrich dealer and get started on your next off-road adventure.

About BFGoodrich Tires

BFGoodrich Tires is dedicated to providing high performance tires for those who have a passion for driving in virtually any environment. Combining technical expertise with 50 years of motorsports experience, BFGoodrich delivers tires for a full range of driving experiences from ultra-high-performance street to off-road terrain with one common theme – extreme performance. Come upgrade your performance with BFGoodrich and see where our tires can take you at BFGoodrichTires.com and BFGoodrichRacing.com, as well as on Facebook, X (formerly Twitter) and Instagram at @BFGoodrichTires.

For more information contact:
Andrew Festa
andrew.festa@michelin.com
Press Officer

McLean, VA – May 1, 2024 – BBB National Programs’ Children’s Advertising Review Unit (CARU) today issued a new compliance warning on the application of CARU’s Advertising and Privacy Guidelines to the use of Artificial Intelligence (AI).

The CARU compliance warning puts advertisers, brands, endorsers, developers, toy manufacturers, and others on notice that CARU’s Advertising and Privacy Guidelines apply to the use of AI in advertising and the collection of personal data from children.

The warning states that CARU will strictly enforce its Advertising and Privacy Guidelines in connection with the use of AI and the potential risks that its use may pose in terms of manipulative practices, including influencer marketing, deceptive claims, and privacy practices. Additionally, according to the warning, marketers should be particularly cautious to avoid deceiving children about what is real and what is not when engaging with realistic AI-powered experiences and content.

“Our Compliance Warning stresses the importance of responsible advertising and data privacy practices in the children’s space, particularly in AI-driven advertising and data collection,” said Dona Fraser, Senior Vice President, Privacy Initiatives at BBB National Programs. “We call on marketers, brands, and developers to prioritize transparency, safety, and compliance with CARU’s Advertising and Privacy Guidelines as we all work to maintain the well-being of children as AI becomes commonplace.”

CARU’s Guidelines are widely recognized industry standards designed to assure that advertising directed to children is not deceptive, unfair, or inappropriate for its intended audience and that, in an online environment, children’s data is collected and handled responsibly. CARU monitors child-directed media to ensure compliance with its Guidelines, seeking the voluntary cooperation of companies and, where necessary, referral for enforcement action to an appropriate federal regulatory body, usually the Federal Trade Commission (FTC), or to a state Attorney General. 

CARU’s Advertising Guidelines

CARU’s Advertising Guidelines apply to advertising in all media, regardless of whether AI is used to create or disseminate the ads, including digital worlds where altered, simulated, and synthetic content is powered by AI.

Brands using AI in advertising should be particularly cautious of the potential to mislead or deceive a child in the following areas:

• AI-generated deep fakes; simulated elements, including the simulation of realistic people, places, or things; or AI-powered voice cloning techniques within an ad.
• Product depictions, including copy, sound, and visual presentations generated or enhanced using AI indicating product or performance characteristics.
• Fantasy, via techniques such as animation and AI-generated imagery, that could unduly exploit a child’s imagination, create unattainable performance expectations, or exploit a child’s difficulty in distinguishing between the real and the fanciful.
• The creation of character avatars and simulated influencers that directly engage with the child and can mislead children into believing they are engaging with a real person.

CARU’s Advertising Guidelines also noted that advertisers should take measures when using generative AI to depict people to ensure the depictions reflect the diversity of humanity and do not promote harmful negative stereotypes. 

CARU’s Privacy Guidelines

CARU’s Privacy Guidelines apply to online data collection and other privacy-related practices for online services that target children under 13 years of age, and to operators that have actual knowledge they are collecting personal information from children under 13 years of age.  

Because AI offers unique opportunities to interact with children who may not understand the nature of the information being sought or its intended use, brands using AI in online services should be particularly cautious in the following areas:

• Requirements and responsibilities when collecting personal information from a child under the Children’s Online Privacy Protection Act (COPPA).
• Reliance upon third-party generative AI technology to operate and process data, which may require verifiable parental consent (VPC). 
• Operators who input a child’s personal information into an AI system and receive a deletion request from a parent, which may be nearly impossible to retrieve and delete.  
• AI-connected toys and online services must collect VPC and properly disclose their collection practices in their Privacy Policy, prior to any collection, use, or sharing of children’s personal information through their own online service or with a third-party generative AI service. 

View CARU’s AI Compliance Warning here.

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About Children’s Advertising Review Unit: The Children’s Advertising Review Unit (CARU), a division of BBB National Programs and the nation’s first Safe Harbor Program under the Children’s Online Privacy Protection Act (COPPA), helps companies comply with laws and guidelines that protect children from deceptive or inappropriate advertising and ensure that, in an online environment, children’s data is collected and handled responsibly. When advertising or data collection practices are misleading, inappropriate, or inconsistent with laws and guidelines, CARU seeks change through the voluntary cooperation of companies and where relevant, enforcement action.

Contact Information:

Name: Jennie Rosenberg
Email: jrosenberg@bbbnp.org
Job Title: Media Relations