CARU Issues Compliance Warning Regarding Children's Advertising in the Metaverse

BBB National Programs' Children's Advertising Review Unit issued a Compliance Warning, advising marketers that CARU's advertising guidelines apply to advertising in the metaverse.  The warning emphasizes that its guidelines apply to all advertising, in any medium, directed to children under the age of thirteen.  

CARU's director, Mamie Kresses, explained, "Our warning puts advertisers, brands, influencers and endorsers, developers, and others on notice that CARU’s Advertising Guidelines apply to advertising in the metaverse and that BBB National Programs' CARU will strictly enforce its Guidelines against metaverse advertising."  

CARU advised that advertisers should be "particularly cautious" in the following areas: 

• Avoid blurring advertising and non-advertising content.  CARU explained that, "advertising can be seamlessly woven into interactive gaming, entertainment, and educational content, along with the blending of influencer marketing and user-generated content, across increasingly connected spaces" and that, as a result, "the risk of blurring advertising and content is intensified."  CARU warned that its guidelines require that "advertising must be easily identifiable as advertising."  
• Influencer and endorser advertising must be clearly disclosed.  CARU explained that, "influencer marketing, including through avatar influencers that can interact directly with children to promote brands, creates potential confusion as to whether influencers are advertising or simply expressing their own preferences."  CARU warned that advertisers and influencers are responsible for the claims they make and for ensuring that their disclosures of material connection are clear and conspicuous.  
• Manipulative tactics in advertising are prohibited.  CARU explained that, "the risk of manipulating children into unwittingly viewing ads or making purchases is heightened where advertising is interwoven into children’s content."  CARU warned that, under its guidelines, "advertising directed to children cannot use manipulative tactics to induce children to view or interact with advertising or make in-game purchases."  CARU also noted that its guidelines prohibit the use of "practices that put undue social or emotional pressure on children."
• Use clear and conspicuous disclosures.  CARU also emphasized the importance of ensuring that disclosures of material information are clear and conspicuous.  CARU explained that, "disclosures must be understandable to the children in the intended audience, taking into account their limited vocabularies and level of language skills, and must be presented so that they are easily noticeable and prominent so children are likely to see and hear them."

By issuing this Compliance Warning, CARU is sending a clear signal to marketers that advertising in the metaverse is one of its top priorities and that it intends to "strictly enforce" is guidelines in connection with metaverse-related advertising.