Responsible

Marketing
Application Manual

1st edition
Marketing to Youth

1
Introduction
Introduction

The Coca-Cola Company has always taken seriously

its commitment to market responsibly, across the
globe, across all advertising media, and across all of
our beverages. Our Company has been a leader in the
area of Responsible Marketing, particularly with
regard to the marketing practices when children
under the age of 12 years are present. Respecting the
rights of parents and caregivers to make the
appropriate choices for their children is a
cornerstone of our Responsible Marketing Policy.

Responsible Marketing is also part of the four global

business commitments which our Company
announced in 2013 to further contribute to healthier,
happier, and more active communities.
This Application Manual aims to help The Coca-Cola
Company marketers in Europe to self-regulate and
implement their marketing practices in accordance
with the letter and the spirit of the Responsible
Marketing Policy.

3
 TCCC
Responsible
Marketing Overall Principles

The central principle for all responsible marketing

Introduction

communications is that they should be scientifically

valid, legal, transparent, truthful and comply with
locally applicable laws and regulations.

Any marketing communication must be obviously

identifiable as such and never be seen as misleading
or ambiguous.

There are 2 further tenets that guide our responsible

marketing:
1) All our marketing content, messaging, design
and placement is created for an audience of 12
years and above.
2) We will use the power of our brands to inspire
people to live healthy, active lifestyles.

4
Scope of the Manual

This Application Manual is intended for use across

Europe and applies to all the activities which we carry
out in order to market our TCCC portfolio of brands.

If more strict regulations or internal guidelines exist

in a specific country, these must be applied in
addition to the global Responsible Marketing Policy
and the European Application Manual.

This Application Manual cannot cover all complex

situations. Thus, you are encouraged to apply the
spirit of the Policy whilst being mindful of unintended
consequences. Please seek counsel from internal
experts, i.e. Legal, SRA, PAC.

5
 TCCC
Responsible
Marketing Public Commitments

In Europe we have made external commitments on

Introduction

responsible marketing. These have been done to the

European Commission and European H&W
Stakeholders through our European industry
platforms (UNESDA and EU Pledge) as well as
through national platforms to national governments
and stakeholders.

These UNESDA and EU Pledge commitments are

monitored by third party auditors and results are
reported back to the European Commission.

This industry self-regulation has delivered tangible

results in reducing the exposure of children below 12
years to marketing. Maintaining our high levels of
compliance will safeguard our ability to build our
brands with our consumers.

These self-regulatory initiatives are dynamic

frameworks. We listen and engage with our
stakeholders and where possible we evolve our
commitments to respond to changing societal
expectations.

6
UNESDA
Commitments
UNESDA’s mission is to support the growth,
development and understanding of non-alcoholic
beverages at a European level.

TCCC as corporate member has made commitments

to:
• Not advertise our brands in programming aimed at
children under 12 years of age* on TV, in print, or online.

• Not offer our brands for sale in primary schools across

the 28 EU countries.

• In secondary schools, where products are offered for

sale, to sell them in unbranded vending machines and
alongside a full variety and choice of drinks formats
including water, juices and no- and low-sugar varieties.

• Not promote our brands in the digisphere on social

networks aimed at children under 12 years of age*.

• Not use imagery on our own corporate websites that

would appeal to children under 12 years of age.

* defined as more than 35% of the audience consisting of

children under 12 yrs.

See webpage: www.unesda.org/our-actions

7
 TCCC
Responsible EU Pledge
Marketing
Commitments
The EU Pledge is a voluntary initiative of leading food
Introduction

and beverage companies in Europe to change the way

they advertise to children below 12 years of age.

It consists of two main commitments:

• Only advertise food and beverage products that
meet common nutrition criteria OR not to
advertise any products at all, regardless of their
nutrition composition.
• No communication related to products in primary
schools, except where specifically requested by, or
agreed with, the school administration for
educational purposes.

See webpage: www.slideshare.net/WFAMarketers/the-eu-

pledge

8
Brands

The Policy applies to all TCCC owned brands,

regardless of product characteristics – including
water and juices.

For bottler owned / licensed brands pls. consult with

the bottler‘s legal department. To note, CCE and CCH
have also signed up to the UNESDA commitments.

Exemplary / uncomplete list of brands

9
Content
1) Introduction

2) The Policy at a Glance

3) Media

4) Creative Execution

5) Promotions

6) Family Venues

7) Schools

8) Youth Education

9) Packaging

10) Children‘s Products / Brands

11
The Policy
at a Glance
The Policy at a Glance

Policy details include:

• We will not target children under the age of 12
years with advertising for any brand of our
Company. This includes television, radio, print as
well as any type of digital / social media.
• This means that where data is available we will not
buy advertising (any media) if more than 35% of
the audience is comprised of children under the
age of 12 years.
• We will not show children under the age of 12
years drinking and enjoying any of our products
outside of the presence of a parent or caregiver.
• When portraying youth alone in our advertising,
either enjoying our products or not, they will not
be below 12 years of age and they will not look
visibly younger than 12 years.

13
 TCCC
Responsible
Marketing

When not certain if a marketing practice is consistent

The Policy at a Glance

with our Policy or not, use the following questions to

determine whether the practice is in line with the
spirit of the Policy.
Q1: Who is the target for this marketing activity?
Q2: What is the objective of this marketing activity?
Q3: What is the audience composition of this
marketing activity?
Q3a: If data is unavailable, would the content of the
program suggest that more than 35% of its audience
consists of children?

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Media
 TCCC
Responsible
Marketing Television/ Radio/ Print

The Coca-Cola Company will not place any of our

Media

brands‘ marketing in television, cinema, radio and

print programming made specifically for children.
This means that we will not buy advertising in
programs/ media with an audience profile higher than
35% of children less than 12 years of age.
We are sensitive to the fact that children may also be
watching programs with their family, and we make
every attempt to ensure that our advertising is
appropriate for a general audience.

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17
 TCCC
Responsible
Marketing Digital Media

The Coca-Cola Company recognizes the growing use

Media

of the Internet and mobile phones amongst children.

While we believe the Internet can be a wonderful
learning tool and mobile phones may be considered a
necessity, The Coca-Cola Company will not buy
advertising on Internet sites/ mobile phones directly
targeted to children below 12 years of age.
We will not have any communications predominantly
targeting children under the age of 12 on any digital
commercial media, inclusive of all TCCC brand and
corporate sites.

18
Definitions :

Digital media refers to the use to advertise and sell

goods and services in electronic commerce.

It includes the placement of:

Paid Search, Display ads, Marketer-written product
reviews, Online ‘public’ classified ads, SMS/MMS ads
on mobile phones, Bluetooth, ‘Viral’ advertising,
Outdoor video, In-game advertising, Marketer-
endorsed User Generated Content (UGC), Elements
of marketer owned websites, E-mail marketing,
Banner ads, Interactive advertising, Search engine
and blog marketing, Messenger, etc. (see glossary of
terms).

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 Creative
Execution
General guidance

The content for our marketing communications

should never
• Show children visibly younger than 12 years
consuming or being alone in the same visual
frame as one of our drinks.
• Give a misleading impression of the nutritional
benefit of drinks.
• Encourage or condone excessive consumption.
The amount of food & drink shown in a creative
execution must be appropriate to the meal
occasion and number of people depicted.
When showing children under 12 years of age
enjoying our products, they will always be
accompanied by an adult caregiver.

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 TCCC
Responsible
Marketing Age considerations

We will not show children less than 12 years of age in

Creative Execution

any of our advertising without an adult caregiver

being present in the setting/ storyline. This is
independent of whether or not any of our products is
consumed.

When portraying teens enjoying any of our products

they will not be below 12 years of age and will not
visually look like they are less than 12 years old.

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Audio visual executions

As for all media, general principles and age

considerations also apply for audio visual executions.

For audio visual formats specifically, please note that

adult caregivers do not need to be present in every
visual frame of the story in which a child under 12
years appears if the following 2 conditions are
respected:
• An adult caregiver is part of the storytelling or
context.
• The children are not shown drinking any of our
products.

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 TCCC
Responsible Use of fictional
Marketing
characters
Borrowing the equity from third party fictional
Creative Execution

characters (licensed characters, animated or non-

animated) or creating own characters that have
appeal predominantly to children under the age of 12
years and/ or run on children’s media is not permitted.

It is permissible to use fictional characters that have a

broad, general audience appeal and are run on media
that is targeted to teens and adults.

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Movie Tie-Ins

We will not partner with films for cinema if the core

target audience, as defined by local Movie
classification agencies (i.e. British Board of Film
Classification) is under 12 or if we judge the film to
have a strong appeal to under 12 year olds,
regardless of the rating.

We will only partner with films certified as having

universal appeal or requiring parental guidance (U or
PG) if they have a predominately adult audience
composition (less than 35% of viewers are under 12
years old).

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Promotions
Promotions

We will avoid any direct appeal to children to

persuade parents or other adults to buy products for
them or to do anything else that goes expressly
against the wishes or authority of a parent, guardian
or educator.
The commitment essentially means that we will avoid
to encourage “pester power”, or the power of
children to pester their parents (or other adults) into
buying a product or service.
As a matter of fact, advertising of a product through a
direct appeal to children to persuade their parents to
buy, is an illegal practice, against both the EU “Unfair
Commercial Practices” and the TV Without Frontiers
directive on television broadcasting.

27
 TCCC
Responsible
Marketing Promotions

As such, we will not target our advertising and

Promotions

promotional materials directly to children under 12.

However, according to these guidelines, it is possible
that we make parents aware of promotional material/
merchandise, e.g. a polar bear, ball, pencils or
notebooks as giveaway with broad age appeal.
Branded merchandise that is designed to exclusively
engage children is not permitted: items that have
limited age appeal and are highly interactive for
children under 12, such as toys, coloring books, and
character items.
In any case, we recommend to consult your local PAC
/ legal counsel when considering to offer
merchandise that may have appeal to children under
12 years.

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Sampling

We will not target under 12 year olds with any of our

sampling activity. This means carefully selecting the
locations as appropriate to the adult or older teen
audience. We recommend to refrain from sampling in
close proximity to primary or secondary schools or
places primary for children.

We may choose locations that have broad family

appeal accepting that in these instances parents will
assume the gatekeeper role (e.g. supermarkets). We
will not offer samples pro-actively to under 12 year
olds and we will only hand out samples to children if
explicitly permitted by the adult caregiver.

General sampling guidelines apply (e.g. handing out

samples already open, one sample per person, small
pack sizes).

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Family
Venues
Family Venues

Family Venues are defined as venues with a specific

appeal to families. Examples are Theme Parks and
Movie Theaters as well as other Family Leisure
Venues (e.g. Swimming Pools).

Family Venues are considered to be of broad age

appeal because children must always be
accompanied/ supervised by caregivers.

For Family Venues, we will ensure to offer:

- a full range of beverages (including water, juices
and other beverages in both regular and low-
calorie/calorie free versions).
- appropriate container sizes that allow for portion
control.

Commercial advertising, branding and cobranding is

permitted as long as materials are not predominantly
appealing to under 12 yr olds.

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Schools
Our brands at schools

As a global business, we respect and recognize the

unique learning environment of schools.

As such, we are committed to a commercial-free

classroom for primary and secondary schools. This
means that we will not do any commercial advertising
in neither primary nor secondary schools.

Additional guidelines for schools activation:

1. No presence of our brands in primary schools
(for details see next page).
2. In secondary schools,
• We will offer a full range of beverages
including juices and waters.
• Vending machines will be unbranded.
• Educational messages on physical fitness
and balanced nutrition must be agreed with
school authorities.
Please consult with your local legal counsel for
country specific laws and regulations.

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 TCCC
Responsible
Marketing Primary Schools

We will have no presence of our brands in primary

Schools

schools.

This includes:
- No sales of beverages unless explicitly requested
by school authorities. If products are made
available,
- they must be offered in an “appropriate
container size allowing for portion control”.
- Vending equipment must be unbranded.
- No commercial advertising in primary schools
including branding or sponsorships of football
tournaments.

If requested, we will make our full range of products

available in teacher’s lounges or areas with restricted
access to students.

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Secondary Schools
When we offer our beverages for sale in secondary
schools,
• We will make a full range of beverages available
(including water, juices and other beverages in
both regular and low-calorie/ calorie-free
versions).
• They will be offered in an “appropriate container
size that allows for portion control”. Generally
speaking, this should be no more than a serving
size.
• Vending equipment will be unbranded, i.e. free of
any trademarks, symbols or features that identify
Coca-Cola products other than waters and fruit
juices.

In secondary schools we may have educational

messages on physical fitness and balanced nutrition
if agreed with school authorities. These programs
must never be aimed at „selling beverages to
children“.

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 Youth
Education
Youth Education

Our system supports education programs for children

in local communities throughout the world,
particularly initiatives focused on promoting active
healthy living. These programs for children under the
age of 12 years will be unbranded.

For the purpose of transparency, a corporate logo

can be included to inform parents, teachers and
children.

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Packaging
Packaging

We understand that we need to have commercially

attractive packaging.
For brands which are designed specifically for
children, the use of third party fictional characters
(any licensed characters, animated or not) is not
permitted as packaging decoration.
For all other brands, third party or own characters are
allowed as long as they are not predominantly
appealing to children <12yo.

39
Children‘s
Products /
Brands
Marketing of Children‘s
Products / Brands
Our Policy permits us to have products and brands
specifically for children. However, the manner in
which they are marketed (including shelf presence
and packaging) must reflect the spirit of the Policy.
We will not undermine the role of caregivers/parents
in the selection of our products for their families.
However, once parents decide to bring these
products home, we understand that we need to have
products which are attractive and functionally
appropriate for children.
As such, packaging for children can be designed so
that it is available in smaller portion sizes, is easy for
children to open and drink from, and is attractive and
entertaining for children to enjoy.

Graphics and the Use of Third Party Characters:

For products and brands which are specifically
made for children , we will not use third party
characters or movie tie in’s in the design of our
marketing for children’s products. These characters
have existing high child appeal, and are likely to
interfere with parents’ decision making process. This
is against the spirit of our policy.

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FAQs
Q) Many have said that 16 is the age beneath which no
children should be marketed to. Why are you setting your
threshold at 12?
Evidence suggests that children under the age of 12 do not
understand advertising and its persuasive techniques. The
Guidelines are meant to respect the role of parent and
caregivers in making the primary decision of their children’s
consumption choices. The age threshold (under 12) has been
chosen based on overwhelming academic evidence showing
that by the age of 12 children have developed a critical
understanding of the commercial nature and persuasive
intent of advertising. Furthermore, all of the latest, most
comprehensive literature reviews (Ofcom, 2004; US Institute
of Medicine, 2005; Livingstone, 2006; McGinnis et al. 2006)
do not find any convincing evidence that advertising
influences the food preferences, requests, purchasing and
consumption behaviour of children and young people aged
12 and over. While academic research does not find evidence
of causality between advertising and diet or health for
children and young people of any age, it draws a clear
distinction between children under and over 12 in terms of
the influence of advertising on stated food preferences and
purchasing requests. It is in line with this academic
consensus that leading food and beverage companies have
decided to limit advertising to children under 12.

43
 TCCC
Responsible
Marketing

Q) How are you defining “marketing”?

This will, of course, include the traditional forms of
marketing communication. However, the world has evolved
and will continue to evolve in such a way that defining what
is “marketing” has become very complex and complicated.
We are putting forth this assistance manual, so that we can
provide context for our Policy and its application.

44
Q) Do I need to limit my availability of products in movie
theatres that feature many films targeted to children?
Availability is not to be confused with marketing. We can
offer our full array of products in cinemas, because like
restaurants, children are likely to be accompanied with an
adult to assist in their consumption choices.

45
 TCCC
Responsible
Marketing

Q) How can you determine an audience’s composition?

You should do your best working with the available
information and appropriate groups to determine the
composition of an audience. Many media have tracking
mechanisms in place to determine the composition of its
audience by program. When data is not available, use your
best judgment based on the show’s content and appeal to
children in order to determine if the audience would be
comprised of children.

46
Q) The 35% cut off may not be sufficient. Don’t children also
watch many other programs aimed at adults and teens?
None of us live in bubbles, including children. Parents have
said that they want to be the gatekeepers of information and
the primary decision-makers in their children’s consumption.
We want to respect the role they play and avoid any
advertising or marketing directly aimed at children. And, if a
child is watching a program intended for adults, the adults
present have the ability to provide any children with the
information they need to judge the advertising.

47
 TCCC
Responsible
Marketing

Q) Why is The Policy being implemented globally?

As a leader in the beverage industry, we have always tried
to take a responsible approach to marketing
communications and have had policies aimed at
responsible marketing to children for many years.

48
Q) What if in doubt whether a child shown in advertising
visually looks like under 12 years?

The primary guiding principle is that the child must actually

not be less than 12 years of age.
If there is doubt whether the cast for an advertising
production looks above or below 12 years of age, the
decision should be taken pending of the scope of the
activity:
- Local: BU Marketing Director with agreement of BU head
of Corporate Responsibility
- Europe: Group Marketing Director with agreement of the
head of PAC
- Global: Ultimately, the decision would need to be taken by
the Corporate Sustainability Officer

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