The Gambling Commission has announced a probe into sponsorship of Premier League football clubs by online gaming companies. There are concerns over the impact this could have on kids’ attitudes to gambling. Nick Johnson bares the regulator’s hand.
Who: The Gambling Commission
When: January 2007
As part of its January 2007 consultation document on "Gambling advertisements and impact on responsible gambling" (see http://www.gamblingcommission.gov.uk/UploadDocs/Contents/Documents/Advertising%20impact%20on%20responsible%20gambling.pdf), the Gambling Commission is seeking views on the issue of gambling brands on replica football kit.
A number of Premiership football sides currently have gambling brands as shirt sponsors. With replica shirts popular amongst both adults and children, the question has arisen as to whether gambling brands on children's replica kit could amount to a direct promotion to (or by) persons under 18.
The consultation asks for views as to whether gambling logos on children's replica shirts should be banned. An alternative suggestion is that gambling operators should make sure that sponsored clubs make available unbranded versions of the shirts so that parents can choose.
The consultation process closes on 6 March 2007.
Why this matters:
The heading of the relevant section of the consultation paper ("Advertising on children's clothing") might be read as suggesting that kids' clothing has been deliberately targeted by gambling companies as a marketing medium.
However one suspects that, in reality, this is very far from the case.
Certainly the experience of alcohol sponsors has been that, when unbranded replica kit is offered, children are less than impressed and will generally wish to be seen in full, authentic attire.
Under the current CAP Code, marketing communications "should not be directed at people under 18 through the selection of media, style of presentation, content or context in which they appear". The proposed new CAP Code provisions adopt a similar position, albeit with slightly different wording (and with an age limit of 16 for football pools and certain other categories of gambling).
So a key question is whether it is valid to look at children's replica kit as a completely different medium from adult replica kit, if indeed replica shirts are a form of media. Given that many older children will wear adult replica shirts anyway, is this really a relevant distinction?
And will regulation in this area have any meaningful impact beyond giving gambling brands additional cachet amongst children, and putting further pressure on a number of football clubs' already stretched finances?
This is an issue that alcohol brands will also be watching carefully. With alcohol products subject to equivalent restrictions on marketing communications "directed at" under 18s, the potential for a knock-on effect for beer sponsors is clear.