Advertising for a competition for Mooju Milk by Glanbia on various social media platforms contained vibrant blue, pink and yellow graphics. The different flavoured milks also appeared in the top left-hand corner of the posts with handheld mobile phones portraying the same images.
The main headline text read:
“LEISUREPLEX. WIN LEISUREPLEX PASSES FOR YOU & YOUR MATES. SNAP YOUR MOOJU”
The message within the posts read:
“Mooju – Win Leisureplex / Jump Zone passes for you and your mates
Do you fancy heading to Leisureplex for a FREE afternoon of fun? send us a pic of you and your mooju on instagram @moojuflavouredmilk or snapchat @moojumilk to be in with a chance to win.”
The advertisers said that they had strict policies and procedures governing any advertisements and communications to children and took their responsibilities to the ASAI Code very seriously.
They said that the competition gave Mooju consumers the opportunity to win a fun adventure day with their friends by sending an image of a carton of Mooju to the brand’s account on either Snapchat or Instagram. The promotion had been advertised on Facebook, Instagram and Snapchat. Entry had been limited to one per person and limited to those over the age of 16.
The advertisers provided a breakdown of their audience with their response for the information of the ASAI.
The advertisers said that it was of paramount importance to them that their advertising was not targeted at children and they disagreed that their advertising had been irresponsible in any fashion.
The advertisers pointed out none of the four flavours of Mooju featured in their marketing communications were classified as high in fat, sugar or salt (HFSS) and were therefore not restricted from being advertised to children. They provided the following table which they considered to substantiate this fact:
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| Mooju Flavour | A points | C points | A points – C points | If drink scores 1 point or more it is classified as a HFSS |
|---|
| Strawberry | 2 | 2 | 0 | No |
| Chocolate | 2 | 2 | 0 | No |
| Banana | 2 | 2 | 0 | No |
| milk | 2 | 2 | 0 | No |
The advertisers said that all varieties of Mooju were low in fat and naturally rich in both protein and calcium, which were a requirement for the normal growth and development of bone in children. The composition of Mooju was in keeping with nutritional compositional requirements to make these health claims as outlined by the European Food Safety Authority (1)
In Ireland, they said that 37% of girls and 28% of boys between the ages of 5 – 12 years had inadequate calcium intake, with 43% and 23% of teenage girls and boys respectively having inadequate intakes of calcium. The Department of Health (DOH) recommended higher intakes of dairy products for people aged between 9 – 18 years because of the nutrients they are naturally rich in. IUNA data has demonstrated that children and teenagers in Ireland consume approximately 2 portions daily, well below the recommended requirement of 5 portions per day (2) (3)
They said that approximately 50% of the sugar content in Mooju was naturally present in the milk and it was important to note that no single food product could meet all nutritional requirements; this can only be achieved by consuming a varied and balanced diet as outlined in the Food Pyramid by the DOH (4). Mooju can play a valuable role within a balanced diet to help meet the nutritional demands during childhood and adolescence.
To enter the competition the consumer had to be over 16 years old and only one entry per person was permitted, therefore the promotion had not encouraged over consumption and one entry had provided the opportunity to win free group passes to a number of entertainment facilities. This enabled the targeted age group to have fun and socialise with friends.
The advertisers said that Facebook analytics demonstrated that 94% of Mooju’s followers were over the age of 18 and Instagram analytics showed that 82% of followers were over the age of 18. The promotion had been boosted on social platforms Facebook, Instagram and Snapchat at a cross section of Mooju’s social following. Data analytics conducted on the Mooju promotion demonstrated that 94% of consumers who viewed the competition were over the age of 16.
In conclusion the advertisers said that Mooju was not restricted from being advertised to children, the promotion did not encourage excessive consumption or unhealthy dietary behaviours and it could be consumed as a treat. The overall premise of the communication was fun with the prize being both active and social.
Footnotes:
(1) https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0983&from=EN
(2) Irish Universities Nutrition Alliance (IUNA) (2005) National Children’s Food Survey: Main Survey Report. Available online at www.iuna.net
(3) Irish Universities Nutrition Alliance (IUNA) (2008) National Teens’ Food Survey: Main Survey Report. Available online at www.iuna.net
(4) https://www.gov.ie/en/publication/70a2e4-the-food-pyramid/
Complaint not upheld.
The Complaints Committee considered the details of the complaint and the advertisers’ response.
Issue 1
The Committee noted the media involved in promoting the competition and that the advertisers had taken steps to ensure that the competition itself had not been targeted at young children as entrants had to be 16+ to enter. They also noted that only one entry per person was allowed.
The Committee noted that 50% of the sugars contained within the flavoured milks occurred naturally, that they were low in fat, sugar and salt and that they were not considered to be a HFSS product. As only one entry to the competition was allowed per consumer, the Committee considered that there had been no encouragement of unhealthy eating or drinking habits nor an enticement or incentive to purchase large quantities of the product.
The Committee did not consider that the advertising had encouraged an unhealthy lifestyle or unhealthy eating habits in children. Accordingly, they did not consider that the advertising had breached the Code requirement that marketing communications featuring a promotional offer should be prepared with a due sense of responsibility. (8.19).
Issue 2
They noted that the Code in this instance provided that, for children under 16, marketing communications should not seem to encourage children to eat or drink a product only to take advantage of a promotional offer: the product should be offered on its merits, with the offer as an added incentive. As competition was targeted at entrants aged 16 and over, the Committee did not consider that the content was in breach of the Code.
ACTION REQUIRED:
No further action was required in this case.
