Last week, the Federal Trade Commission issued its seventh report in ten years on the marketing of violent media to children. While the movie industry is doing better at preventing children who are underage from buying tickets to R-rated films and DVDs, the report shows that there is still a long way to go, especially with the marketing of PG-13 movies.

With respect to PG-13 movies, studios continue to market these films purposefully and directly to children under 13. In its review of marketing plans and ad placements, the Commission found explicit and pervasive targeting of very young children for PG-13 movies. The marketing overview for the DVD release of one PG-13 movie, for example, described the movie’s “#1 Key Demo” as parents 25 and older and kids 8 to 14….The studios’ marketing submissions for the six PG-13 movies showed that all were heavily promoted to children under 13 in advertising on children’s cable networks – “Kids’ Cable” – and through promotional tie-ins with candy, snack foods, kids meals, toys, and other licensed products.

Studios also conducted marketing research on young children, including in one instance children as young as 7 years old. When research results showed that children and parents were concerned about the level of violence in the film, studios sometimes even altered their advertising to make the film appear less frightening, rather than market to an older audience. One studio, for example, copy tested ads for its PG-13 movie on various age groups, including children ages 7 to 9 and 10 to 12. The studio found that 80% of boys in these age groups showed definite interest in seeing the movie but also found that many parents were concerned that the movie was too violent. The written report stated that “parents, in large numbers, complain about the violence in , saying they wouldn’t want to expose their children to that.” The solution proposed by the studio was to “experiment with spots that include less intense action and more humourous/light-hearted moments in order to convince more parents that , saying they wouldn’t want to expose their children to that.” The solution proposed by the studio was to “experiment with spots that include less intense action and more humourous/light-hearted moments in order to convince more parents that will be safe to see. (emphasis added)

The Campaign for a Commercial-Free Childhood has issued a statement on the report, calling for broader authority for the FTC over the marketing of media to children.

We are pleased that FTC questions the effectiveness of the film industry’s self-regulatory efforts. The report dismisses the MPAA’s much-hyped referral agreement with the Children’s Advertising Review Unit – an agreement the MPAA claimed would address concerns about PG-13 marketing – as “not a meaningful self-regulatory measure.” The report also notes that the MPAA does not consider movie cross-promotions or other marketing tie-ins to be within its purview, despite the fact these techniques are often part of a deliberate strategy to target younger children. In one instance, the FTC found that the target demographic for licensed products was for a violent PG-13 film was boys 3 to 11.

The FTC report also covers the change to the trailer rules I first wrote about in September and the access to “red band trailers” over the internet. Those trailers are shown in theaters only before R-rated movies to assure that they are not shown to children. But online, they are available to anyone.

A new concern in the online venue has been the proliferation of red tag trailers for R-rated movies on websites without adequate age-based restrictions. Mature Audience trailers (for films expected to be rated R- or NC-17) are preceded by a red tag stating that the preview has been approved for “restricted audiences only” and indicating the movie’s rating and rating reasons. Red tag trailers generally contain content that caused the film to be issued a restrictive rating and thus are subject to more stringent time, media, and venue restrictions.

According to the MPAA’s Advertising Administration, red tag trailers on the Internet must be placed behind an age-gate or similar mechanism to ensure that children under the age of 18 will not easily be able to view the material….Five of the six [video-hosting] sites contained at least one red tag trailer for viewing. Two of the websites did not use any age-screening mechanisms before allowing the user to watch the trailers. Even on the three sites that did, the user could circumvent the age gates by hitting the “back” button to the previous page and re-entering his or her age as 17 or older. (footnotes omitted)

The Commission also raised concerns about other issues, including the marketing of “unrated” DVD versions of theatrically released films. I will post additional information about the FTC’s findings on games and music and will also provide updates on any response from the MPAA or other industry groups.