Advertising and children
Advertising and children
1 ADVERTISING TO CHILDREN AS SUCH
1.1 Legal/regulatory framework
1.1.1 General Principles
Prior to 1990, there was very little statutory-based regulation of advertising in the UK. The Advertising Standards Agency (ASA) had been established in 1962 but was (and still is) merely an industry regulator. Whilst the ASA now has significant sanctions available to it, in the event that an advertiser breaches its Code, such as the circulation of adverse publicity and the refusal of media space, it has minimal legal powers of enforcement. Moreover, the Code it applies is arguably as much a control for the benefit of the industry as it is for the protection of the public.
However, following the EC Directive on Television Broadcasting of 1989, The Broadcasting Act 1990 set up a statutory body to monitor standards in the broadcast media. The body was called the Independent Television Committee (ITC) and the Code it enforced was the Code of Advertising Standards and Practice. The Act also introduced the Radio Authority whose role and functions mirrored those of the ITC in radio broadcasts.
Today, the three regulatory bodies continue to operate within their own spheres, such that the ASA monitors the quality of advertising in the print media and in cinema advertising, the ITC regulates television broadcasts and the Radio authority deals with radio broadcasts.
The various Codes applied by the regulatory bodies have some common characteristics, particularly in respect of the principles they seek to uphold in advertising to children. Advertisers are required to have regard to the following factors:
1.1.1.1 Age and Experience
The regulations recognise that a major factor in the ability of people to judge the effectiveness or desirability of a given product or service shown in advertisements is their age. Therefore, if a regulatory body is called upon to judge the suitability of an advertisement, the age and experience of the target audience will be a factor within its contemplation.
1.1.1.2 Physical, Moral or Mental harm
Products should not be advertised in a manner which might result in harm to children of a physical, mental or moral nature. For the purpose of the ITC Code, children are to be regarded as those aged 15 years and under. The ASA Code suggests that situations showing children talking to strangers or in close proximity to dangerous substances are, amongst others, examples of advertising that could cause children harm.
1.1.1.3 Credulity, Loyalty, Vulnerability
Advertisements should not play on the susceptibility of children to peer pressure and the consequent possibility of their feeling inferior or unpopular for not buying the products in question. Furthermore, they should require that adult permission is needed before children are committed to buying costly products.
1.1.1.4 Nuisance
It is a key requirement of the Codes that advertisers should not bring about situations in which children pester their parents or other adult relatives to buy them advertised goods. Direct appeals to buy should be avoided unless the product would be likely to interest the child and he or she could reasonably afford to buy it.
1.1.2 Specific Products
a) Tobacco
Under the ITC Code, tobacco is one of a number of 'Unacceptable Products' which means that the advertising of tobacco products on television is strictly prohibited.
In respect of the non-broadcast media, the ASA has drawn up a distinct set of guidelines (the Cigarette Code) specifically dealing with tobacco advertising. The ASA remains the responsible for applying and enforcing the Cigarette Code; it deals with complaints about adverts and clears adverts before use. Of the rules of the Code which deal with advertising to children, advertisers must not use hero figures or famous personalities where this is likely to appeal to the young. Moreover, cigarette advertising should not seek to attract the attention or sympathy of the under-18s market and therefore any person featured in such an advertisement should be, and clearly be seen to be, over 25 years of age.
b) Alcohol
The rules relating to alcohol in advertising are remarkably similar across the Codes. Advertisements should be socially responsible and should not seek to exploit the susceptibilities of the young. For example, they should not imply that refusal to drink is a sign of weakness, nor that to drink is an essential attribute of masculinity.
Advertisements should not be directed at the under-18s and the content and style of presentation of the advert should not be attractive to this age group. No medium should be used to advertise alcohol where more than 25% of the audience is under 18. People shown drinking should not be, or appear to be, under 25 years of age.
c) Toys
The ASA Code does not deal explicitly with the matter of advertising toys but it is clear that some of the general principles will be relevant. For instance, the principle that adverts should not exploit the credulity, vulnerability or lack of experience of a child, in particular by making them feel inferior or unpopular for not buying the product, is bound to be of significance. The requirement that the advert should make it easy for the child to judge the size, characteristics and performance of a product and that a child should easily be able to distinguish real life from reality is equally important.
The ITC Code deals with similar issues under the broad heading, misleadingness. It states, "Children's ability to distinguish between fact and fantasy will vary according to their age and individual personality. With this in mind, no unreasonable expectation of performance of toys and games may be simulated by, for example, the excessive use of imaginary backgrounds or special effects." The paragraph goes on to detail some of the factors that will be relevant in determining whether the advertisers have duly complied with their obligations. They include, the ease with which the size of the toy can be judged, the extent to which any comparison of the toy with its real life counterpart has been made and, where advertisements show the results of a construction kit or such like, whether the average child could reasonably have attained those results.
d) Medicines
Under the ITC Code, no advertisement for a medicinal product may be directed at people under the age of 16. The ASA Code states simply, advertisements for medicines should not be addressed to children.
e) Food
The ASA declares that advertisements should not encourage children to engage in late night eating habits or to think that snacks are suitable substitutes for proper meals. The ITC chooses to concentrate more on considerations of oral health. Advertisers should not encourage frequent consumption of food throughout the day (particularly of products containing sugar) and should not "depict situations where it could be reasonably assumed that teeth are unlikely to be cleaned overnight after consumption, eg midnight feasts."
f) Dangerous products
The ITC Code states that:
Medicines, disinfectants, antiseptics and caustic or poisonous substances must not be shown within reach of children without close parental supervision, nor may children be shown using products in any way;
Children must not be shown using matches or any gas, petrol, paraffin, mechanical or mains powered appliance which could lead to them suffering burns, electrical shock or other injury.
Furthermore, television adverts for, inter alia, matches, should not be transmitted during children's programmes or in the advertisement breaks immediately before or after them.
g) Health/beauty products
Both the ASA and the ITC state that advertisements for slimming products must not be addressed to people under 18 or use elements likely to be of particular appeal to them. Further, the ITC 's guidance note no. 12 on audience indexing (the identification of programmes likely to appeal to children and young people) identifies slimming products, treatments and establishments among several products which "must not be advertised in or adjacent to children's programmes or programmes commissioned for, principally directed at or likely to appeal particularly to audiences below the age of 18."
h) Other
Other restrictions under guidance note number 12 on the products that must not be advertised during and around children's programming include bingo and certain religious matter (to audiences below 18); lotteries and pools (to audiences below 16); and female sanitary protection products (to audiences below 10).
1.1.3 Leading precedents
The Benckiser case is an adjudication by the Advertising Standards Authority on a complaint relating to dangerous products:
Benckiser Ltd: Several members of the public objected about a free sample of stain remover tablets being distributed through letter-boxes. The sample included a free trial tablet which was enclosed in foil-backed plastic. The label on the wrapper clearly stated, "IRRITANT. Avoid contact with eyes and skin. Keep out of reach of children". However, the complainants argued that to distribute the sample in this way was irresponsible because it endangered children.
The advertisers explained that they consulted a specialist sample pack producer and Trading Standards to ensure that the sample was child-resistant and suitable for mailshot distribution. The Authority considered that due care had been taken in the production of the sample packaging and concluded that it would be difficult for a child to open the foil-backed plastic wrapper. Complaint not upheld.
1.1.4 Ways of Advertising
i) Direct Marketing
The Codes do not restrict the ability of the advertisers to market their products to children directly but, under the ITC Code, no advertisement may invite children to purchase products by mail or telephone.
j) TV-Radio
In addition to the measures dictating the content of advertisements which are designed to protect children, the ITC also has guidelines as to the times when advertisements for certain products can be transmitted. Adverts for alcoholic drinks, liqueur chocolates, matches, medicines, vitamins and slimming products, must not be transmitted during children's programming or in the advertisement breaks immediately before or after them. Furthermore, popular figures associated with children's television programming must not be shown advertising products before the watershed of 9pm.
Of course, the general principles of the Codes are always relevant, so adverts of an adult nature, (containing, for instance, violence or sexual innuendo) "which might result in harm to [children] mentally or morally", must never be shown at times when large numbers of children are likely to be viewing.
The approach of the Radio Authority is to put the onus on the licensees to ensure that advertising that is transmitted is appropriate to the time and the potential audience.
k) Internet
Advertising carried on the internet is the subject of regulation by the ASA. There is nothing in the Code that prevents an advertiser from directing advertisements at children on the net provided that they adhere to the usual regulations.
l) Lotteries/Games
Apart from the age-restriction enforced by the state for participation in the National Lottery and its associated 'scratch card' games (minimum 16 years), there are few restrictions on the freedom of advertisers to appeal to a child audience by use of lotteries/games. However, both Codes give some direction as to the means that should be employed. Under the ITC Code, for instance, "if there is to be a reference to a competition for children in an advertisement, the published rules must be submitted in advance to the licensee. The value of the prizes and the chances of winning one must not be exaggerated."
The Advertising Standards Authority is more specific in terms of the restrictions it places on advertisers. "Promotions addressed to children:
(a) should not encourage excessive purchases in order to participate;
(b) should make clear that adult permission is required if prizes and incentives might cause conflict. Examples include animals, bicycles;
(c) should clearly explain the number and type of any additional proofs of purchase needed to participate, tickets for outings, concerts and holidays;
(d) should contain a prominent closing date;
(e) should not exaggerate the value of prizes or the chances of winning them."
m) Sponsorship
There are no restrictions on the freedom of advertisers to associate their products with events or TV programmes. However, the general principles will apply, with the effect that events which are attended by large numbers of children, or programmes that are watched by a child-centred audience, must be sponsored by appropriate commercial partners.
n) Premises
The kinds of premises on which large numbers of children are likely to assemble, such as schools and youth clubs, are also likely to be private property, so any advertising that takes place on the premises will be in the control of the land owners/licensees.
With regard to schools, it is likely that billboard advertising of, say, tobacco products in the immediate vicinity of the school, would be regarded as a breach of the ASA Code.
o) Magazines
No particular rules deal with magazine advertising to children.
p) Other – Children in Advertising
The ITC Code has rules on the use of children in advertising. One presumes that this is not only for the protection of young actors, but also for the benefit of watching children who might naturally pay closer attention to child presenters.
First, children in advertisements should be reasonably well-mannered and well-behaved. Secondly, child presenters should not present products or services they would not be expected to buy themselves, whether or not such products are of interest to them. Nor may they make in relation to any product or service, significant comments on characteristics of which they cannot be expected to have direct knowledge. Thirdly, children must not be used to give formalised personal testimony. This does not, however, preclude children giving spontaneous comments on matters in which they would have an obvious natural interest.
1.1.3 Leading precedents regarding above
The following adjudication by the ASA relates to a complaint about the use of violence in an advertisement found in a magazine, which could easily be viewed by young children:
Future Publishing Ltd: Readers objected to a magazine advertisement that stated "Tired? Listless? In need of a boost? Take one of these new, easy to swallow Future Gamer capsules. Dosage: One per week". In the bottom left hand corner was "WARNING: Contains Humour" and a visible footnote read "Future Gamer: a magazine covering PC PlayStation and N64 games".
The complainants considered that, because it was placed in a magazine that was read by children, the advertisement was irresponsible and encouraged children to regard drugs as fun and use them as a cure for boredom and fatigue. The advertisers said they had apologised to one of the complainants for the offence caused. They thought the advertisement was ill-advised and had withdrawn it. They apologised for the content of the advertisement and gave their assurance it would not be repeated.
The Authority considered that the advertisement was likely to be seen as referring to drug taking and, especially because of the young age of the magazine's target audience, the Authority concluded that the advertisement was irresponsible. It welcomed the advertisers' assurance that they would not use the advertisement again.
Complaints to the Independent Television Committee often relate to the time at which an advertisement was broadcast. ie. That the content of the advert was not suitable for a child-centred television audience:
Handbag.com: Two viewers, from the Central and Carlton areas, objected to the showing of an advertisement for Handbag.com on the 23 and 29 May in the morning between 10:00 and 12:00, on the grounds that its violent content was inappropriate at times when children might be watching.
The advertisement showed a woman take a sub-machine gun from her handbag and shoot her car. There were four advertisements for this company and the BACC had applied a post 19:30 timing restriction to this version. Carlton sales, who were responsible for scheduling this advertising in both regions, explained that through human error the correct timing restriction had not been applied on this occasion. They apologised for any distress caused.
Complaints upheld. The ITC were concerned that the timing restriction had been missed but judged that no regulatory action was justified in the absence of any evidence that this was other than an isolated error
2. Advertising of Specific Products destined for Children by use of characters.
2.1 Cartoons and similar characters
Advertising of toys, magazines, clothes and similar merchandise to children by use of cartoons and similar programme/product tie-ins.
(a) Are there any legal restrictions at all to use famous cartoons or other fantasy characters, such as Disney characters, Pokemon and Star Wars characters in advertisements to children? If yes, develop legislation and/or precedents. If no, is there any legislation/self regulation in progress?
Such legal restrictions as exist are contained in the Independent Television Commission Code of Advertising Standards and Practice (the ITC Code).
The UK Broadcasting Act 1990 makes it the statutory duty of the ITC to draw up and enforce a code governing standards and practice in television advertising and the sponsorship of programmes. The Code is drawn up with regard to the EU Directive on Television Broadcasting (89/552/EEC of 1989 as amended by Directive 97/36/EC of 1997) and the 1989 Council of Europe Convention on Transfrontier Television.
Under the ITC Code fictional characters who regularly appear in any children's television programme broadcast on any UK television channel may not be shown before 9pm in any advertisement presenting or positively endorsing products or services of particular interest to children.
Importantly, the characters covered by this provision are those which have come to be known through a television programme as opposed to through advertising. This means that while Tom & Jerry or Bugs Bunny cannot be used in advertisements prior to 9pm., fictional characters like Quaker Sugar Puffs' Honey Monster, or the Stay Puff Marshmallow Man that have become well known as a result of their appearance in advertising campaigns, are not so restricted. Public service advertisements are exempt from this provision and there are no restrictions on using any characters or personalities that might appeal to children for this type of advertisement.
Referring to the examples in the question ie Disney, Pokemon and Star Wars characters, the first question to ask is whether these are characters that regularly appear in children's television programmes broadcast on any UK television channel.
What constitutes regular appearance for these purposes? What is a UK television channel? The ITC Code states that these provisions do not apply "to programmes which are not currently on air and have not been carried on any channel for a period of at least two years". The definition of a "UK television channel" is not so clearly set out. However, the ITC Code "applies to all television programme services licensed by the ITC under the Broadcasting Act 1990 and the subsequent Broadcasting Act 1996. At present these are Channel 3 (ITV and GMTV), Channel 4, Channel 5, satellite television services provided by broadcasters established in the UK, licensable programme services ( which include those cable channels established in the UK which are not also in any of the licence categories just referred to), digital programme services and services provided under Restricted Service Licences" and the Welsh fourth channel."
So, in order to say whether or not the characters in our example can or cannot be used in broadcast advertising before 9pm we would have to analyse the broadcasting history of all the channels in this category. As the number of television channels falling within the definition of "UK television channel" continues to grow, checking this could be a monumental task. We would guess, however, that most Disney and all Pokemon characters are likely to be caught and could not therefore be used in pre 9pm advertising.
Separately, if an advertisement is for merchandise based on children's programmes, it must not be broadcast in any of the two hours preceding or succeeding transmission of the relevant programme or of episodes or editions of the relevant programme.
So far as non broadcast advertising is concerned, there are no specific legal restrictions in this area, nor do the principal self regulatory codes governing non broadcast advertising in the UK, the British Codes of Advertising and Sales Promotion, make specific reference to use of fictional characters.
(b) Are there any restrictions on programme/product tie/ins on broadcast of children's programmes which feature characters already commercially available as toys? If yes, develop legislation and/or precedents. If no, is there any legislation/self regulation in progress?
There is no outright ban on such tie-ins, though up until recently it was the ITC approach that the programme must precede the product. In other words, if products are already commercially available as toys in UK shops, no subsequently launched children's programming featuring them prominently will be allowed.
In recent years, however, this line has been dropped. The ITC Code of Programme Sponsorship now states that if a programme features characters which are the subject of commercially merchandised or licensed products, the programme must not be funded in any way whatsoever by the product manufacturer or licensee (or their agent). This is because if such an arrangement were behind the making of the programme, this would be considered to be sponsorship and the programme would be regarded as having an unacceptable promotional purpose.
A connected rule, also in the Programme Sponsorship Code, is that close similarity between a programme's content and an advertiser's advertising might constitute grounds for regarding the programme as having an unacceptable promotional purpose. This is likely to be the case, the Code goes on, if a character created for advertising or marketing purposes is developed for use in a programme. Moreover, this will apply regardless of whether the adertiser is involved in making the programme or not.
Famous persons
Advertising of services or products to children by use of famous persons.
(c) Are there any legal restrictions at all on the use of famous persons such as athletes, pop stars, people known from TV, actors in advertisements to children? If yes, develop legislation and/or precedents. If no, is there any legislation/self regulation in progress?
There are no legal restrictions as such in this area, but again the ITC Code comes into play by stipulating that advertisements in which personalities who appear regularly in any children's television programme on any UK television channel, present or positively endorse products or services of particular interest to children must not be transmitted before 9pm.
A more general ITC Code restriction prevents the use, either visually or orally, in any advertising on UK commercial TV of any person who regularly presents news or current affairs programmes on any UK television service. This would clearly extend to ads directed at children.
A related general rule, again in the ITC Code, is that TV advertisements which include a person who also appears, other than in a minor or incidental capacity, in a programme, may not be scheduled in commercial breaks in or adjacent to that programme. Again this would apply to children's programmes as much as to other categories of programme.
There are no specific rules in this area in the non broadcast advertising, self regulatory British Codes of Advertising and Sales Promotion.
In a radio advertising context, station presenters/newsreaders are permitted by the Radio Authority Advertising and Sponsorship Code to voice commercials, including commercials directed at children, (the Radio Authority and the Radio Authority Code being the commercial radio equivalent of the ITC and the ITC Code) provided they do not
(i) endorse, recommend, identify themselves with or personally testify about an advertiser's products or services
(ii) make reference to any specific advertisement when in their presenter role.
We are not aware of any impending relevant legislation or self regulation which might change this position other than proposals recently published (May 2000) by the ITC for a more relaxed regime in certain areas including two relevant to this paper.
Firstly, it is proposed to relax the rule forbidding advertisements for merchandise based on children's programmes during two hours before or after the programmes in question.
The ITC comments that the rule was introduced partly to address concerns about advertising likely to encourage children to "pester." It questions, however, whether , provided the advertising does not "overtly encourage" pestering and is in all other respects compliant, any greater level of protection is required. It also remarks on the fact that in any event children are increasingly exposed to programme-related merchandising as a result of homes with multi channel TV and internet access.
In the circumstances the recommendation is that instead of the two hour restriction, the standard scheduling restriction be adopted. This would, in this case, keep advertising for products which are versions of programme characters and the like away from the breaks within or immediately before or after that programme. This is on the basis that the ITC would remain vigilant to prevent the direct juxtaposition of an advertisement for a product with a glamorous presentation of that product in a programme.
Secondly it is proposed to relax the ban on visual or oral featuring in TV advertising of regular news or current affairs programme presenters. It is still proposed that there should some restrictions but a graduated approach taking onto account the level of exposure presenters have in news programmes and regional considerations is suggested.
2.2 Children
(a) Advertising of products or services by the use of children
The British Code of Advertising and Sales Promotion contains a raft of general rules relating to the use of children in advertising featuring or addressed to children. The two questions below distinguish between advertisements directed at adults and those directed at children. However these general rules apply to both, so we will summarise them here.
Nothing in an advertisement featuring a child should contain anything that is likely to result in their physical, mental or moral harm. They should not be shown in a sexually provocative manner and if they are to be partly or completely undressed then this should not be exploitative. Children's manners and behaviour must be reasonably good and they must not be encouraged to make a nuisance of themselves, to parents or to others. Children should not be shown in dangerous situations, such as entering strange places, talking to unknown people, alone in the street (unless they are "old enough", but we are not told how old is "old enough"), near fires (if the fire is in the home there must be a fireguard), or handling matches or other dangerous substances (e.g. petrol, medicines), near machinery or electrical appliances, or leaning out of windows and so on. The lists go on but the general principle is clear that children must not be shown in dangerous situations or be encouraged (whether by other children or adults) to copy actions that could be dangerous for them and the age of the children involved can be taken into account when determining whether or not a situation is dangerous.
In the same vein, the ITC Code contains broadly similar restrictions to the depiction of children in advertising, regardless of the target market. Particular aspects of the ITC Code are referred to below.
2.3 To adults
(a) Are there any legal restrictions at all to use children in advertisements to adults, e.g. regarding decency, nudity or specific products such as nappies, children's wear etc? If yes, develop legislation and/or precedents. If no, is there any legislation/self regulation in progress?
The ITC Code states that advertisements must not portray children in a sexually provocative manner and that treatments in which children appear naked or in a state of partial undress require particular care and discretion.
Separately, advertising in which children are shown being given medicine, vitamins or any other dietary supplement cannot be shown before 9pm unless the Commission approves of the circumstances in which they are shown. The same time restriction applies to advertisements for this type of product which use cartoons, toys, characters or any other mode of presentation or advertising technique that may be of special interest to children. Further, children must not be shown administering any of these products to themselves unless the Commission gives prior permission.
These rules are consistent with a general provision of the ITC Code which states that "children must not be used formally to present products or services which they could not be expected to buy themselves." It is of no consequence whether or not the product or service being advertised is or could be of interest to them, Further, they cannot make comments on the product or service of which they cannot be expected to have direct knowledge of, or to give formalised personal testimony in relation to products or services, although it is permitted for children to give "spontaneous comments on matters in which they would have an obvious and natural interest."
(b) If so, are there any relevant precedents confirming the situation?
One example of the application of the ITC rule against children being used in a sexually provocative manner was in relation to TV advertising in 1996 for the Safeway supermarket chain. The ITC received 19 complaints about an advertisement featuring 2 tots in which the boy said to the girl "No chance of a snog then?". The ITC ruled against the complaints, saying the references, employed in a light hearted manner, did not constitute adequate grounds for intervention."
In another case, a Peugeot advertisement, again in 1996, showed a child being borne down on by a lorry until, at the last minute, being swept to safety by an adult. Complainants were concerned about the child being shown in a situation which was detrimental to road safety. Again, however, the ITC threw the claim out.
2.4 To children
(a) Are there any legal restrictions at all to use children in advertisements to children, e.g. regarding decency, nudity or specific products such as toys etc? If yes, develop legislation and/or precedents. If no, is there any legislation/self regulation in progress?
The advertising of toys and games is constrained by a number of measures. The underlying principle which actually applies to all products and not just to toys is that the vulnerability and immaturity of children should not be exploited in order to sell them products and services. They should not be made to feel inferior or as if they are failing if they do not buy the product advertised. In particular the actual size of a toy or game should be easy to judge. This might be done by showing the product against an everyday object so that the child can understand the actual size. The functionality of a toy must not be overstated but rather must be demonstrated in a way which the average child could use the toy. For example, it would be unfair to suggest to all children that a five year old can build a giant fully functioning water mill from technical Lego bricks, whereas the average 12 year old may well be able to create such a masterpiece, but it would not be fair to suggest that it could be built with one box of Lego.
This brings us on to the question of how the child may acquire the products or services and pricing. There must be no direct extortion of children and children must not be pressed to ask parents to make purchases for them, although there are circumstances when children should be encouraged to communicate with parents about the subject matter of the advertisement, for example parental permission should be sought before using the telephone. The latest guideline on this point is from the International Federation of Direct Marketing Associations which states that all companies must get parental consent before accepting any contractual orders from children or collecting any personal data from them.
Under the ITC Code advertisements may not ask children to use mail telephone or e-mail to purchase products. Advertisements to children must show the price of the product if it is "expensive." What is expensive? This is determined by the Commission from time to time and was last set on 30 March 2000 at £25.00.
A related rule is that it is sufficient, where there is a range of products being advertised, to show only the price of the most expensive product. If the decision is made, however, to show other prices then each product must be clearly associated with its price. The ITC Code goes even further and provides that where the product requires extras, the normal example being batteries, then the advertisement must say so, and the price cannot be shown with words which may have the effect of minimising the cost, such as "only and "just"
2.5 Controls of use of children in advertising
(a) Are there any controls over employment of children as actors in advertisements, e.g. number of hours they can be required to work, authorisations/permissions needed etc?
There are specific controls relating to the employment of children as performers, and these will naturally apply to short appearances in ads as much as they will to their appearing in feature films.
In essence these require that any advertiser wishing to use child performers (for these purposes under 16's) must obtain a licence from the child's local authority, even if the child only works in this connection for one day in a year. This applies to the use of children for voiceovers as well as live action, but a licence is not required if the child is not going to be paid and only, for example, receives expenses.
Some local authorities are understood not to require licences for children under school age, but others do, and the only safe course is to apply for licences in all cases.
Other restrictions are that the child may not be required to perform for more than 5 days including rehearsal days in any period of seven days. There also other detailed rules including regulations covering the number of hours children can be required to work depending on the child's age, the number of days a child can be required to perform in a year and taking a child out of the UK for shooting purposes.
