• by Ross Fadner , October 6, 2003

Many in the ad business see it as a solution to ad-zapping technologies, but the so-called practice of product integration into TV programming came under official government scrutiny last week. In a complaint filed with the Federal Trade Commission, Commercial Alert, a public advocacy group backed by Ralph Nader, requested the federal government investigate the wave of product placements and other undisclosed product pitches that have begun infiltrating TV shows.

The complaint singles out ABC, CBS, NBC, Fox, UPN, the WB and Walt Disney Co. for failure to comply with sponsorship identification requirements. Gary Ruskin, author of the complaint and executive director of Commercial Alert, asserted product placement and plugs are a deliberate ploy on the part of advertisers to mislead consumers into thinking such products are part of regularly scheduled programming.

But agency executives contacted by the MediaDailyNews countered that these accusations are driven by wrong-headed logic, and challenged Commercial Alert's fundamental assertion that advertising and commercialism are not in the public interest. More importantly--federal scrutiny notwithstanding--, media buyers said the effort likely will fall on deaf ears.

"I don't think anything will come of [the complaint]," said Brad Adgate, Senior Vice President and Director of Research at Horizon Media. "On-air product placement is merely a throwback to the early days of TV and movies. Certainly there is no harm in placing a product on a set so long as it works naturally with a given story line."

Laura Caraccioli-Davis, Vice President-Director at SMG Entertainment, agrees, adding, "Products are absolutely essential to a set. They give it authenticity. Without them, a kitchen or living room on set wouldn't look like a real kitchen or living room at all.

In the complaint, Ruskin cites pre-existing sponsorship identification requirements made by the FCC, hoping to highlight hypocrisies in the execution of its rules: "Paramount to an informed opinion and wisdom of choice, is the public's need to know the identity of those persons or groups who elicit the public's support;" a broadcast audience must "be clearly informed that it is hearing or viewing matter which has been paid for..."

But this comes as no surprise to advertisers, who are well aware of the FCC's rules regarding product deals. "All product deals have to follow rules," said SMG's Caraccioli-Davis, "the FCC has a standards and practices ruling implemented for the placement of embedded products which agencies and networks must-and do-adhere to."

Ruskin also made the claim that identifying sponsors only once-at the end of each program-is insufficient to match the subtle and complex efforts of embedded advertising.

"It is inherently deceptive because [such advertisements are] often below the viewer's threshold of awareness," he said. To remedy this, Commercial Alert suggested a 'paid advertisement' message be placed at the bottom of the screen for as long as the product appears. In addition, the group suggested sponsors should be indicated at the outset and end of each program.

Horizon's Adgate said he couldn't disagree more. "There is so much ad clutter. Identification of sponsorship as the products are being displayed would do nothing but add to the clutter."

He noted this would be to the detriment of everyone concerned because it would offend consumers. "Product placement is not and should not be about adding to ad clutter. It's simply about branding, and in most instances viewers understand this," explained Adgate.

SMG's Caraccioli-Davis also pointed out that the Commercial Alert effort appears to ignore the most the most important constituent in the effort: consumers themselves. "The bottom line is that the consumer has been completely left out of the equation by Mr. Nader's group. If you asked an 18-24 year old consumer if we should pull "Survivor" or "American Ido" because of undisclosed product placement they would say no. They have the filtering capabilities to decipher these messages anyhow, and they don't seem to have a problem with product placement. So I don't think Commercial Alert's objections will have much of an effect on industry procedures and practices."