FTC Renews Call to Entertainment Industry to Curb Marketing of Violent Entertainment to Children

Marketers of violent music, movies, and video games can do more to restrict the promotion of these products to children, according to the seventh in a series of Federal Trade Commission reports on marketing violent entertainment to children.

“The Commission has been reviewing and reporting on the movie, music, and video game industries’ advertising and marketing practices relating to violent entertainment for 10 years now,” noted FTC Chairman Jon Leibowitz in a separate statement accompanying the report. “Despite considerable improvements, the self-regulatory systems are far from perfect.” He also emphasized that “in the future, it will be particularly important to address the challenges presented by emerging technologies – such as mobile gaming – that are quickly changing the ways that children access entertainment.”

The FTC’s report states that the music industry still has not adopted objective marketing standards limiting ad placement for explicit-content music. As a result, the industry still advertises music labeled with a Parental Advisory Label (PAL) on television shows viewed by a substantial number of children. Music retailers routinely sell labeled music to unaccompanied teens.

The report also finds that movie studios intentionally market PG-13 movies to children under 13, and the movie industry does not have explicit standards in place to restrict this practice. The growing practice of releasing unrated DVDs undermines the rating system, and confuses parents.

Both the video game and movie industries can do more to limit ad placement on Web sites that disproportionately attract children and teens, according to the report.

Since the FTC issued its first report on marketing violent entertainment to children in 2000, the agency has called on the entertainment industry to be more vigilant in three areas: restricting the marketing of mature-rated products to children; clearly and prominently disclosing rating information; and restricting children’s access to mature-rated products at retail. This latest report found areas for improvement among music, movie, and video game marketers, but credited the game industry with outpacing the other two industries in all three areas.

Parents who want to know more about how entertainment for children is rated can visit ftc.gov/ratings. This site describes the different ratings systems, and provides links to the organizations that sponsor them.

“Marketing Violent Entertainment to Children: A Sixth Follow-up Review of Industry Practices in the Motion Picture, Music Recording & Electronic Game Industries” analyzed information from sources including marketing documents submitted by industry members, an undercover “mystery” shopper survey, consumer surveys conducted in shopping malls and by telephone, “surfs” of industry Web sites, and data acquired from proprietary ad-monitoring services. Findings include:

• Music: While the music industry’s Parental Advisory Label alerts parents to explicit lyrics in recordings, it does not provide information about the nature of that content. The music industry has declined to implement rules restricting the marketing of explicit-content labeled music to children. The report does not find any indication of specific targeting of children, but does show numerous examples of ads for explicit-content music on television programs popular with teens. Disclosure of the label in advertising is still spotty, including on official artist and company Web sites, where the label usually is not readable. Television ads display the explicit content label only half the time, and even then usually not prominently. Music CD retailers and online download sites, by contrast, do an excellent job of displaying the parental advisory label. Finally, retailers do not effectively prevent children from buying explicit-content music, with seven in 10 underage shoppers able to buy CDs with a Parental Advisory Label.
  
  
• Movies: Although the movie industry determines on a case-by-case basis whether a PG-13-rated film may be advertised to children under 13, there is no explicit policy restricting such marketing. As detailed in the marketing plans reviewed by the Commission, movie studios targeted violent PG-13 films to children under 13 both through advertising and promotional tie-ins with foods, toys, and other licensed products. Studios continued to place a significant number of ads for violent R-rated movies on television shows and Internet sites highly popular with children under 17. Increasingly, industry members post “red tag” trailers for R-rated movies, intended for age-restricted audiences, on the Internet without age-based access restrictions. Although the MPAA rating and rating reasons are not always prominent, the industry generally does display the MPAA rating in advertising. Rating information on DVDs is not prominently placed; moreover, more and more DVD versions of movies are not rated, and some studios hype the lack of a rating. The Commission’s research shows that parents are not adequately informed that unrated DVDs may contain additional violent or adult content. On the positive side, theaters denied 72 percent of underage shoppers admission to R-rated movies, a significant improvement from 2006 and even more so from 2000. Most retailers, however, continue their poor record of enforcement against underage purchase of R-rated and unrated DVDs.
  
  
• Electronic Games: The FTC finds a high degree of compliance with the video game industry’s marketing and advertising rules, although these standards allow game
  marketers to advertise on many television shows and Web sites popular with children. Further, retailers are enforcing age restrictions on the sale of M-rated games to children, with an average denial rate of 80 percent. The report notes, however, that children may be able to obtain M-rated games by, for example, using retailer gift cards online. Finally, the proliferation of game applications for mobile devices provides challenges – for example, some companies do not provide any rating system for games available on their networks, and there is no consistent system of age-based parental controls for these applications.

The Commission recommends these measures to strengthen the entertainment industry’s self-regulatory programs and better restrict the marketing of violent entertainment to children:

• The movie and music industries should develop specific and objective criteria to restrict the marketing of violent movies and music to children. Specifically, marketing of PG-13 movies to young children directly and through tie-ins with foods, toys, and other licensed products should be restricted. All three industries should tighten restrictions on online and viral marketing.
  
  
• The movie industry should increase enforcement against online posting of “red tag” trailers without adequate age-based access restrictions, and should ensure that the content of “appropriate audience” trailers is consistent with the feature films they will precede.
  
  
• All three industries should improve their display of rating information in advertising and packaging. The movie industry should place the rating and rating reasons on the front of DVD cases and disclose rating information prominently in all advertising venues. The music industry should display the Parental Advisory Label more prominently in advertising, particularly in television and online venues, and it should provide information about the specific type of explicit content. The electronic game industry should include content descriptors with the rating on the front panel of game packaging and continue to provide more detailed rating summaries for parents online.
  
  
• The movie industry should better inform parents about additional adult content in unrated DVDs and give parents a way to evaluate unrated versions. The industry should consider re-rating DVD releases or, at a minimum, expand new disclosure rules for unrated DVDs.
  
  
• Gaps in enforcement of age-based sales restrictions for movies, music, and electronic games should be closed, and enforcement challenges created by the use of gift cards for online purchases should be addressed.

The Commission vote to approve the report was 4-0. Chairman Jon Leibowitz issued a separate statement, which can be found on the FTC’s Web site and as a link to this press release.

Copies of the report are available from the FTC’s Web site at http://www.ftc.gov and also from the FTC’s Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580. The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,700 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s Web site provides free information on a variety of consumer topics.