Sanoma Media Finland violated the Consumer Protection Act: direct invitation to purchase Sanni concert tickets in Aku Ankka

Aku Ankka magazine advertised tickets to Finnish artist Sanni’s concert in a manner that contravened the Consumer Protection Act. The print advertisement in the magazine was not identifiable as an advertisement, and the AR competition had a direct invitation to purchase targeted at children. The Consumer Ombudsman pointed out the matter to Sanoma Media Finland, the publisher of Aku Ankka magazine, and the company has committed to acting in accordance with the position of the Consumer Ombudsman.

An issue of Aku Ankka (i.e. Donald Duck) magazine included a story about a cartoon character based on the artist Sanni as well as an article about the singer. Under the article, there was a competition advertisement where the reader was encouraged to use an AR application to find a virtual Sanni in the magazine and win tickets to her concert. The advertisement did not differ visually much at all from the related article, even though editorial and marketing material must be kept separate especially in publications aimed at children.

As both the competition and the concert were approved for all ages, and Aku Ankka (i.e. Donald Duck) is geared towards children with regard to genre, subject matter and content, both advertisements must be considered to have been aimed at children.

– Nowadays, marketing uses more and more new kinds of formats, such as augmented reality. The principles of consumer protection also apply to these new forms of advertising, says Consumer Ombudsman Katri Väänänen.

Printed advertisement was not clearly an advertisement: marketing for children requires special care

Marketing targeted at minors is assessed more strictly than other marketing, as children are particularly impressionable due to their age. It is likely more difficult to identify an advertisement the younger the reader is.

Although the competition advertisement in Aku Ankka was marked as an advertisement and contained a mention of the commercial cooperation, it was not clearly identifiable to children as an advertisement. The appearance of the article and the advertisement were similar to each other and were placed next to each other. The title and body of the advertisement used the same fonts and colours as the article, which made the advertisement less identifiable. In addition, the visual cartoon-like elements of the illustrations fit in the style of Aku Ankka magazine and were particularly attractive to minors.

The identification of the advertisement may have been made even more difficult by the fact that the comic featuring Sanni started on the same spread, and the advertisement stated that the story goes beyond the magazine. This may have created the impression, especially for children, that the advertised competition would add more content to the story. “Find and seek” type games are part of children’s experience of the world and can therefore attract children’s interest.

“Click here and get tickets” – children were encouraged to buy concert tickets

The competition in the magazine was carried out using augmented reality (AR). The reader would download an AR application to their phone and use it to scan the panels of the Sanni story, and then the application would superimpose video material of Sanni over the panels. The videos included numerous comic-like visual elements and sound effects.

At the end of the story, the application showed a wheel of fortune where the reader had a chance to win tickets to Sanni’s concert. If the reader was not lucky enough to win, a link popped up next to the wheel of fortune encouraging the reader to “check out the tickets”. In the same situation, virtual Sanni encouraged the reader to “click here and get tickets”. According to the Consumer Ombudsman, this is a direct invitation to purchase, especially because it was possible to purchase tickets from the associated link.

– Commercial messages may not be hidden in other communications. After downloading the AR app in the advertisement, instead of getting a fun find and seek competition, you got marketing with a direct invitation to purchase, says Väänänen.

Consumer Ombudsman’s decision KKV/54/ (in Finnish)

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