Confectionary

The posts on the advertisers’ Facebook page referred to the following:
Post 1
This post was accompanied by an image of a takeaway hatch. The signage over the hatch contained an image of a Cadbury’s creme egg and read “IT’S HUNTING SEASON”. People were featured on their way up and down to the hatch to get their creme eggs. The text above the imagery read:
“Cadbury Dairy Milk
We’re on the hunt today in Kilkenny! Find us at Parade Plazza where you can pick up some gooey Creme Egg treats from our takeaway hatch for just €2.
#CremeEggHuntingSeason”.
Post 2
The second post was accompanied by the Cadbury logo alongside an image of a toasted sandwich with a Cadbury Creme egg melting on top. The text above the image read:
“Cadbury Dairy Milk
Creme Eggs with breakfast?! Goo on…#CremeEggHuntingSeason”.

The complainant said that she considered Easter time to be of particular appeal to children and the possibility was, that children alongside adults, would view the posts. She said that she considered the posts to be irresponsible in content.
Complaint – Post 1
The complainant said she considered that the post was encouraging people to take part in the #CremeEggHuntingSeason as a matter of urgency, to avail of the promotional offer on the Creme eggs. She considered that the promotion was encouraging people to consume an unhealthy amount of the product.
Complaint – Post 2
The complainant said that she considered the advertisement to be condoning poor nutritional habits and an unhealthy lifestyle to children. She said to encourage the eating of Creme Eggs for breakfast for either adults or children was in her opinion unhealthy advice.

The advertisers said that they never marketed their products directly to children under the age of 16 and their promotional campaigns were always targeted at adults. They said they took their responsibilities very seriously when it came to marketing their products, they abided by the relevant codes and were fully compliant with the EU Pledge(1). They also ensured that their staff were fully aware of the applicable rules and they had set up an eLearning training module to cover the topic.
Complaint – Post 1
The advertisers said that the Creme Egg Event had been aimed at adults and had provided information about upcoming events in the lead up to and over the Easter weekend 2018. The event referenced in this post ran in support of the wider Creme Egg campaign. Tickets to the event in question could only be purchased by people over the age of 16 years. Children under 16 had to be accompanied by an adult at the ratio of one adult to two children. Those who had tickets had been afforded the opportunity to attend the Creme Egg themed lodge as well as a clue ‘hunting’ activity and a kitchen hat (canteen).
The advertisers said that those who attended the ticketed event had the choice of selecting one treat from the Creme Egg themed menu (the majority of items were below 300 calories per serving). They said that while some of the items on the menu had also been available to purchase, to make a purchase one had to be over 16. The advertisers said that they had not created a sense of urgency in relation to their event nor had they promoted excessive or irresponsible consumption of their products.
The advertisers said that their reference to “It’s Creme Egg Hunting Season” had referenced the positioning of their Creme Eggs seasonal availability i.e. at Easter time. The reference to ‘Hunting’ had also drawn further awareness to the other events which ran around the Easter period.
Complaint – Post 2
The advertisers said that the image of the toastie provided in their second post had been created in accordance with their internal nutritional guidelines. These guidelines took portion control into account, alongside calorific energy and nutritional values. They said their post had never suggested replacing breakfast on a permanent basis with a Cadbury Creme Egg Toastie. They said the intention of the post had been to provide inspiration for alternative recipes and ideas as to how the product could be consumed over Easter. They said each toastie had used no more than one Cadbury Creme Egg. They considered, therefore, that the product had been depicted in a moderate portion size and had not encouraged an unhealthy lifestyle or unbalanced eating habit.
In conclusion the advertisers said that their Facebook post had promoted the toastie in question as a treat which was best enjoyed occasionally as part of a balanced diet. They said they had never encouraged excess consumption of the product or poor nutritional habits in either adults or children.

FURTHER INFORMATION
The ASAI Executive noted from internet research (2) that a Cadbury Creme Egg Toastie had the following nutritional profile:
Per Serving:
Calories 457.0 kcal 22.9%
Fat 19.7 g 28.1%
Saturates 11.8 g 59.0%
Salt 1.2 g 20.0%
Sugars 28.6 g 31.8%

% of your Guideline Daily Amount (GDA). To be enjoyed as part of a healthy, active lifestyle.

Typical Values Per Serving
Energy 1914.0 kj
Energy 457.0 kcal
Fat 19.7 g
Carb 64.8 g
Protein 7.4 g
Saturated fat 11.8 g
Salt 1.2 g
Dietary fibre 1.2 g
Sugars 28.6 g

The Executive also noted that the average daily calorie intake for men is approximately 2,500 calories and for women it is 2,000 calories.(3) The Executive also noted that that the Cadbury Creme Egg Toastie had a calorie content of 457.0 kcal per serving. This represented approximately 18% and 23% of adult male and female recommended daily intake respectively

FOOTNOTE:
(1) http://www.eu-pledge.eu/: The EU Pledge is a voluntary initiative by leading food and beverage companies to change the way they advertise to children. This is a response from industry leaders to calls made by the EU institutions for the food industry to use commercial communications to support parents in making the right diet and lifestyle choices for their children
(2) https://www.cadbury.co.uk/recipes/creme-egg-toastie-249774
(3) www.irishhealth.com/askdoc.html?q=4732&qasect=3

Complaint not upheld.
The Complaints Committee considered the details of the complaint and the advertisers’ response. They recognised that the advertising in question related to Easter 2018 but that some of the imagery used was also being used in the Easter 2019 Campaign.
Complaint – Post 1 – Not upheld
The Committee noted that the event in question had been a ticketed event that had been targeted at adults prior to the Easter period. They noted that if children had been in attendance, they had to be accompanied by an adult. They also noted that each person who had attended received only one treat of their choice from the menu provided. The Committee accepted that the offer related to the Easter period but did not consider that, in itself, had created a sense of urgency to avail of the offer. The Committee did not consider that Post 1 had breached the requirements of the Code and did not uphold the complaint.
Complaint – Post 2 – Not upheld
The Committee noted the advertisers’ explanation that the product was intended to be consumed as a treat around the Easter period. They also noted the use of an exclamation mark alongside the question mark in relation to the query posed “Creme Eggs with breakfast!? They considered this to indicate that what was being offered was somewhat out of the ordinary.
While the Committee considered that it would have been preferable to have included a reference to occasional consumption or similar, the Committee considered on balance that the post was not in breach of the Code.

ACTION REQUIRED:
No further action was required in the matter.
The Committee asked that the advertisers take note of their views in relation to post 2.