The CAA Copy Panel approves cinema commercials in line with the advertising codes applicable in the UK of Great Britain and Northern Ireland, and the Republic of Ireland respectively.
These codes are the UK Non-broadcast Code of Advertising, Sales Promotion and Direct Marketing (the CAP Code) which can be downloaded here, and the Code of Standards for Advertising and Marketing Communications in Ireland (the ASAI Code) which can be downloaded here.
Both codes are interpretable in light of the medium to which they apply. This means an advertisement approved for TV broadcast in the UK or the Republic of Ireland is not automatically approved for cinema exhibition in either country.
Not all commercials are suitable for a general audience. Due to subject, treatment or the product advertised, it is sometimes necessary to ensure a commercial will only be seen by an audience of an appropriate age profile. This is achieved by restricting the commercial to run only with feature films having an appropriate or higher classification.
The UK classification system administered by the BBFC rates films as U, PG, 12A, 15 and 18. Descriptions of what each category signifies can be found at www.bbfc.co.uk.
The Republic of Ireland classification system administered by the Irish Film Classification Office rates films as G, PG, 12A, 15A, 16 and 18. Information on these categories can be found at www.ifco.ie.
The CAP codes are subject to change, and The CAA needs to ensure that adverts continue to comply with these changes. To ensure this, CAA final approval is valid for a period of 12 months from the date of issue. If you wish to exhibit an advert that is out of validity, please ensure you log on to your account and resubmit the content as a ‘revision of a previously submitted item’. This applies even if none of the content has changed from the previously approved advert. If there are changes made to the advert but are non-substantive static changes, such as addition of onscreen text, logo the submission is not chargeable.
Restrictions to the advertising of high fat, salt and sugar (HFSS) drinks and foodstuffs apply to UK and Republic of Ireland (ROI) cinema advertising.
Note that the UK comprises Great Britain and Northern Ireland.
It is the obligation of the advertiser to inform the CAA if the product or brand they wish to advertise in the UK or ROI is HFSS or not. This is done through a field on the submission form.
The form asks if a product is HFSS. If the ‘No’ box is ticked, the HFSS certificate substantiating this must be emailed, with details of the advertisement in the email subject line, to [email protected]
The certificate substantiating the non-HFSS nature of the product is required for both UK and ROI cinema advertising. This is because many advertisements are common to both countries requiring only minor changes, e.g. voice-over or currency, to render them appropriate for their respective audience.
In the UK, an HFSS product may only be advertised with feature films achieving a national audience profile of no more than 25% under-16s.
In the ROI, an HFSS product may only be advertised with films achieving a national audience profile of no more than 50% under-15s.
The category of a film does not necessarily determine the profile of the audience it may attract. The CAA therefore uses independently gathered statistics to create predictive national audience profiles for forthcoming feature films. From this, the CAA generates a list of imminent feature releases which may not carry HFSS advertising. This list is updated and issued every two months.
With the exception of those for fresh fruit and vegetables, all food ads – HFSS or not – addressing any age group should not use terms such as ‘good’ or ‘goodness’ in a manner that implies health-giving qualities, e.g. ‘good for you’. In referring to the quality of flavour, advertisers should use phrases like ‘taste good’. Portions shown for individual consumption must be modest, and fresh fruit or vegetables must not be denigrated.
Advertisers have three options in regards to cinema PEGI requirements that must be added to gaming copy. One of the three following options: A voice-over opening or onscreen text accompanying PEGI cert stating; ‘This game has been certified PEGI (xx)’ or onscreen text accompanying PEGI cert stating ‘Game rating’.This is to avoid confusion with the BBFC certificate of the accompanying feature film.
Both CAP and ASAI codes stipulate that advertisements for electronic cigarettes may not be shown with any feature film whose national audience profile exceeds 25% under-18s.
Additionally, the presence of nicotine in any e-cigarette liquid must be indicated with a strapline. In the event of a range of liquids being available for the product, a proportion of which contain nicotine, the strap must state ‘some e-cigarette liquids contain nicotine’.
In the Republic of Ireland it is not permitted to advertise spirits in the cinema. From 12 November 2019 alcohol advertising in the Republic of Ireland is only permitted with 18 classified films. This is due to the 'Public Health (Alcohol) Act 2018' passed by the Dáil in October 2018.
In the UK, the advertising of alcoholic drinks is permitted with feature films attracting a national audience profile of 25% or fewer under-18s.
The category of a film does not necessarily determine the profile of the audience it may attract. The CAA therefore uses independently gathered statistics to create predictive national audience profiles for forthcoming feature films. From this, The CAA generates a list of imminent feature releases which may not carry alcohol advertising. This list is updated and issued every two months.
Under the CAP and ASAI codes, gambling and lottery advertising are two distinct forms of advertising.
In Great Britain (England, Wales and Scotland) gambling advertising, including advertising for casinos, must not accompany feature films attracting a national audience profile of more than 25% under-18s. This also applies to Northern Ireland but with the additional restriction that casinos may not be advertised in cinemas in that province.
Throughout the UK, lottery advertising must not accompany feature films attracting a national audience profile of more than 25% under-16s, except National Lottery products.
From the 1st October 2021, the targeting and scheduling rules for National Lottery products has been raised from 16 to 18 years old. This is due to DCMS raising the minimum age of sale for all National Lottery products. This new restriction only applies to National Lottery products and not to other lotteries (social lotteries) which still have a minimum participation age of 16 and are restricted as such.
In the Republic of Ireland, gambling advertising currently follows similar restrictions to those for Northern Ireland. Lottery advertising is subject only to the general ASAI codes.
Advertisers producing copy requiring supplementary information (straplines) are advised that although television line-height standards are acceptable, these may appear unacceptably large on the cinema screen. For information on cinema minimum line-height standards please contact The CAA.
Advertisers are reminded that all claims made in their commercials must be supported by robust, independent substantiation to the level required by the CAP or ASAI Codes. The applicable rules are to be found in subsections of the CAP Code Misleading advertising section and ASAI Code Misleading advertising section.
The CAA Copy Panel considers any toy priced at £15 or €15 to lie beyond pocket money purchase. Advertisements for toys priced over this limit must carry an indication of their cost in the appropriate currency or currencies. In the case of electronic games aimed at under-16s, it is necessary to indicate if in-app purchases are required in order to play the game adequately. This is of particular importance if the initial game is claimed as being free to download.
Any advertisement affiliated with a government body or initiative, or public information awareness, where the intention of the advert is not to sell a product (e.g. TFL, Police Federation, Drink Drive Awareness, Mayor of London, Government Tourism advertisements [not just UK]) must submit content to the BBFC and The CAA. The BFFC charge for the submission of Public Information adverts – The CAA do not. When you submit a Public Information advert to The CAA, please ensure you select “public information” as the payment method. Please note that following a Public Information submission, The CAA will need to verify the advert to ensure it complies with necessary criteria, and is exempt from payment.
Claims in marketing communications, whenever published or distributed, whose principal function is to influence voters in a local, regional, national or international election or referendum are exempt from the Codes. However, marketing communications by central or local government, as distinct from those concerning party policy, are subject to the codes.
Cinemas or cinema chains have their own policies regarding the screening of political advertisements which seek to influence voters. Advertisers wishing to exhibit such ads in cinemas should first contact CAA member companies to ascertain the possibility of them being screened.
The CAA can advise on other aspects of this type of political advertising, such as decency elements.
Religious commercials are fully subject to the codes. However, cinemas or cinema chains have their own policies regarding the screening of religious advertisements. Advertisers wishing to exhibit such ads in cinemas should first contact CAA member companies to ascertain the possibility of them being screened.