Toy Association Opposes ISO Work Item That Ignores Existing Advertising to Children Codes

June 21, 2021 | The Toy Association recently submitted comments to the American National Standards Institute (ANSI), urging ANSI to oppose an International Organization for Standardization (ISO) proposal to develop a standard for advertising and marketing to children. ISO’s new work item ignores the existing and well-regarded codes and programs already in place in the United States and globally to effectively govern advertising and marketing to children and teens.

“Protecting children and maintaining the trust of parents are the most vital concerns for the toy industry,” stated Steve Pasierb, president & CEO of The Toy Association, in the submitted comments. “Accordingly, The Toy Association monitors and reviews relevant laws and standards pertaining to responsible marketing and advertising to children, educates its members about these principles, and provides resources that help toy companies interact with children in a responsible way. ISO’s new work item proposal is unnecessary, incomplete, and duplicative of an existing globally recognized International Chamber of Commerce Code for marketing and advertising, adopted in 42 countries. The proposed standard would demand, and waste, countless hours and resources of all stakeholders to develop this unnecessary guidance.”

From the U.S. perspective, there is a robust system for self-regulation that has been in place for decades. The Children’s Advertising and Review Unit (CARU) Guidelines, first issued in the 1970s and updated many times since, establish a recognized framework of best practices for marketing to children in the United States. The principles of the CARU Guidelines are very much in keeping with those in the ICC Code. The U.S. FTC has also recognized CARU’s self-regulatory children’s privacy program as a “Safe Harbor” under FTC’s Children’s Online Privacy Protection Act (COPPA). COPPA, enacted in 1995, was the first children’s privacy law in the world.

Toy Association members are encouraged to reach out to ANSI to express their opposition of ISO’s proposal as soon as possible to help illustrate the unnecessary nature of this work and potential impact on companies of all sizes. As the U.S. member of ISO, ANSI will develop a U.S. position based on the input received. Any member that wishes to weigh in is welcome to reference The Toy Association comments, and/or those of the International Chamber of Commerce (ICC), in their outreach. Comments to ANSI should be addressed to Steven Cornish (scornish@ansi.org).

At the international level, companies may also raise the issue with the ISO national member body in those countries. Since ISO operates on a “one country, one vote” system, similar outreach should be done in as many countries as possible. A link to the list of ISO member organizations, by country, can be found here.

ISO will vote on the proposal in July; however, the national member bodies of ISO have already begun collecting input on the issue, and they may set their own internal deadlines for input, so the timing is urgent. Non-governmental organizations in many countries are rallying in support of this proposed standards effort and are keen to make laws for advertising to children mandatory around the world. The Toy Association and its counterparts in opposition are challenged by the fact that they are well organized and have made this an emotional issue – underscoring the need for opposition in all countries to speak up.

Questions on this matter may be directed to The Toy Association’s Leigh Moyers.