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Stop Product Placement

January 5, 2010

Register your concerns before Friday (see earlier post). For what it’s worth, here are mine…

Dear Mr Gandy,

I write to express strong opposition to your department’s intention to relax the legislation on product placement.

In particular, I see no reason why the last consultation on this matter (March 2009) should so quickly be revisited. Recent submissions from the BMA, NUT, Which?, The British Heart Foundation, The Church of England, and indeed advertising’s own IBSA reflect widespread concern about this legislation, which I hope the government will take seriously.

I also write as a Friend of Breathe, a Christian Network for Simpler Living (www.breathenetwork.org). Breathe connects over 600 people who, while appreciative of the benefits of the modern economy, seek to mitigate some of the negative effects of consumer culture.

Product placement on UK-produced TV programmes would represent an erosion of the public broadcasting space, and the trust on which that space thrives. It depends on the creation of subliminal, often unjustified, mental associations (Calvert and Silberstein 2007, and popularised in Martin Lindstrom’s book Buy-ology). As such, product placement has no place in responsible broadcasting and certainly falls short of the Department of Culture Media and Sport’s aim to promote ‘quality of life’.

In response to the consultation document, I would argue for the strongest safeguards possible, including a full legal safeguard of programmes with high child audience figures; the prohibition of advertising for gambling, alcohol and HFSS foods; and the exemption of religious, news, consumer and current affairs programmes.

However, it seems obvious that the safeguards being considered would have very little effect. Your own consultation document notes the difficulty of enforcing controls on pre-recorded, pre-scheduled programmes. Insisting on low product prominence is, of course, absolutely no deterrent against the subtle effects of association which product placement aims to foster. The questions raised about acceptable genres (and how to define them), and what constitutes a disproportionate number of child viewers, demonstrate that once product placement has been allowed it will be very difficult to contain. Companies will, in effect, be invited to investigate just how far they can go to influence viewers through programming which bears no direct relation to their product. The editorial process will undoubtedly be affected by the concerns of advertisers.

Advertising is a necessary and creative element in a consumer economy, but the government’s role should be to keep it from overwhelming or unduly influencing our media.

If the department wishes to be true to its aim it will maintain the current ban on product placement.

Yours sincerely,

Mark Powley

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