UK ASA thinks “sponsored by” isn’t sufficient disclosure for pure ad

 
A video entitled “Easy Lip
Makeup Tutorials for Winter Time” viewed on the “Beauty
Recommended” You Tube channel [owned and run by P&G], featured a model
vlogger. It showed the vlogger talking about and using a number of Max Factor
products, as well as products from other brands, in the context of a lip makeup
tutorial. At the beginning of the video text appeared which stated “Sponsored
by BEAUTY RECOMMENDED, brought to you by Procter & Gamble”. The video
description, which could be viewed in full by clicking the text “SHOW
MORE” beneath the video, summarised the content of the video, listed all
six Max Factor products featured and included a link to buy the products via
the online shop “SuperSavvyMe”. Text at the bottom of the description
stated “Sponsored by BEAUTY RECOMMENDED, brought to you by Procter &
Gamble”. . . .
 
We considered that viewers should
have been aware of the commercial nature of the content prior to engagement.
Furthermore, we considered that “sponsored by” and “brought to
you by” did not make clear the marketing nature of the videos. Although
they might indicate to some viewers that Procter & Gamble had been involved
in the process, they did not clearly indicate that the videos were marketing
communications, as opposed to, for example, material that had been financially
sponsored, but over which the creator retained editorial control. For those
reasons, we considered that consumers would not be aware that the videos were
ads promoting Procter & Gamble, and instead were likely to believe the
videos were impartial editorial content. We concluded, therefore, that the
videos within the “Beauty Recommended” channel, including the “Easy Lip”
tutorial, were not obviously identifiable as marketing communications.

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