Video blogging (vlogging), where individuals provide video blogs on an ever-expanding range of topics, has grown exponentially in recent years. Vloggers are able to reach a potentially huge target audience by posting their videos on online content sharing channels. According to Your Life (http://yourlife.org.uk), an industry-led, government-backed campaign that aims to inspire young people to study Maths and Physics at A Level, teenagers increasingly see vloggers as role models. A report published by Your Life suggests that nearly a quarter of 11 to 19 year-old girls (24%) see the fashion and beauty vlogger Zoella (who has over 6.5 million subscribers to her YouTube channel) as a role model, and a brief scroll through the comments posted under this vlogger’s videos shows the influence she has.
The rise of vlogging presents advertisers with increased opportunities to promote their products to a wider audience. However, there have been a number of reports highlighting the fact that, when vloggers promote products in their videos, it is not always made clear to the viewer they are watching an advert. CAP have therefore released clear guidance aimed at vloggers, to ensure that they understand how and when the advertising rules apply to their vlogs.
The guidance follows a ruling last year in which a number of vlogs were found to be misleading because they did not make clear before viewers watched the videos that the vlogger had been paid to promote the product they featured. The ASA stressed that promotions should be clearly marked as such, with Lynsay Taffe stating: "Vloggers often have huge followings built on authenticity, built on them providing interesting, funny, natural content…We think it's only fair that when they start promoting stuff on behalf of a brand - which is absolutely fine for them to do - that they do so in a way that's clear and upfront with their audience."
The advertising rules state that adverts must be obviously identifiable as such. These rules apply across media including online and to social media channels, so clearly apply to vlogs. If a vlogger is paid to promote a product or service and an advertiser controls the message then the video will constitute an advert. If this is the case, vloggers must be upfront and clearly signpost that they are advertising a product, rather than endorsing it on their own behalf.
The new guidance highlights a key rule of the CAP Code, which is that if content is controlled by the marketer, not the vlogger, and is written in exchange for payment (which could be a monetary payment or free items) then it is an advertisement feature and must be labelled as such (rule 2.4). The guidance covers a number of areas, including online marketing by a brand, “advertorial” vlogs, commercial breaks within vlogs, product placement, vloggers making videos about their own products, editorial video which refers to a vlogger’s products, sponsorship and free items. The guidance is clear and comprehensive, and provides clear information to vloggers and marketers regarding how to comply with the advertising rules.
The rules apply to advertisers and agencies as well as to vloggers. Advertisers and agencies must not ask vloggers to conceal the fact that they are advertising a product. Advertisers and agencies who ask vloggers to do this are asking them to break the advertising rules and potentially the law.