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CARU Issues Compliance Warning Regarding Children’s Advertising In The Metaverse – Social Media

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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

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

  • Avoid blurring advertising and non-advertising
    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
    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
    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.

Originally Published by Advertising Law Updates

This alert provides general coverage of its subject area. We
provide it with the understanding that Frankfurt Kurnit Klein &
Selz is not engaged herein in rendering legal advice, and shall not
be liable for any damages resulting from any error, inaccuracy, or
omission. Our attorneys practice law only in jurisdictions in which
they are properly authorized to do so. We do not seek to represent
clients in other jurisdictions.

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