Online Retailer

A series of posts on Dealz Ireland’s Facebook page, promoting the “Elf Behaving Badly” Christmas campaign featured the following imagery:

a) The first image featured the toy elf holding a tea bag between its legs over the face of a female doll lying on the ground.

b) The second image featured the toy elf holding a spherical shaped object and a Darth Vader toy holding a lightsabre.

The complainant said he considered the imagery used to be sexualising childrens’ toys which he found degrading in content.

The advertisers said they considered their customers in Ireland liked to laugh and that is why they prided themselves on bringing creativity to their low cost advertising campaigns. They said at Dealz they do not like to take themselves too seriously and look to bring moments of fun and laughter to their customers when they can.

The advertisers said they were disappointed that a complaint had been made about their “Elf Behaving Badly” campaign and that it was never their intention to cause offence with their posts. They said they had received significant positive feedback from people who had viewed the humour as they had intended it to be viewed. They said their “Elf Behaving Badly” campaign was based on humour, something they said that Irish people were famously known for. The advertising was based on double entendres which they considered would go over the heads of those who did not understand them and make those that do [understand them] laugh out loud. They said that their campaign was always intended for adult consumption, the nature of a double entendre being that it would not be understood by children.


In relation to the campaign sexualising a children’s toy, they strongly challenged this as “Elf Behaving Badly” was, they said, not marketed as such.

In conclusion the advertisers said they had been mindful when creating their campaign for social media channels that such platforms had policies in place that prevented under -13s from creating accounts on their website. They never sought to encourage anyone other than adults to follow their posts through their social networks.

Complaint upheld.

The Complaints Committee considered the detail of the complaint and the advertisers’ response. The Committee noted that the toy depicted in the advertising was similar to the “Elf on the Shelf”, a children’s toy based on a book of the same name.

The Committee considered the two posts complained of. They considered that both posts, one featuring the Elf holding a teabag over another doll’s face and the other the Elf holding an object resembling an adult toy were obvious references to sexual acts.

Whilst noting the advertisers’ comments that the platforms involved required users to be aged 13 and over, the Committee did not consider that to sexualise children’s toys was compliant with Section 3.3 of the Code and they upheld the complaint.

ACTION REQUIRED:
The advertising should not run in the same format again.