The OPC complained that the ad breached the Quick Service Restaurant Initiative for Responsible Advertising and Marketing to Children (QSRI) as it was a communication directed primarily to children and an interactive game including KFC fried chicken, not representing a healthier dietary choice consistent with the QSRI’s Nutrition Criteria. The OPC also argued that the ad breached the AANA Code for Advertising & Marketing Communications to Children (Children’s Code) as it was an advertising or marketing communication to children and it encouraged and promoted unhealthy eating habits. Finally, the OPC argued that the ad breached the Food & Beverages Advertising & Marketing Communications Code (Food & Beverages Code) as it undermined the importance of healthy lifestyles and healthy balanced diets and encouraged excess consumption.
The advertisement was an interactive Snapchat lens featuring KFC’s Buckethead. It enabled users to take a photo with a virtual KFC Buckethead imposed over it. The lens included an ‘open your mouth’ trigger, with the KFC Buckethead spinning and flying chicken exploding into fireworks.
The OPC argued that Snapchat should be considered an interactive game, as well as an internet site, under the QSRI.
The ASB held that Snapchat was a medium covered within the definition contained in the QSRI. However, the ASB held that Snapchat is not a medium that is directed primarily to children or where children would comprise more than 35% of the audience – because Snapchat requires an account holder to be over 13 years old. Although the Snapchat game was promoted on a stadium billboard on the final game of the Big Bash League (cricket match), the Board considered this would be a largely adult audience, although children would be included. With respect to whether the content of the Snapchat ad was directed primarily to children, the ASB held that the bucket lens would appeal equally to an adult audience and there were many other filters available on Snapchat that are more childlike.
Under the Children’s Code, the ASB held that for the same reasons as applied under the QSRI, the Snapchat ad was not directed primarily to children so the Children’s Code did not apply.
Under the Food & Beverages Code, the ASB held that promotion of a product which may have a particular nutritional composition (in this case, high fat and sodium) is not of itself undermining the importance of a healthy or active lifestyle. As there was no chicken consumed in the ad, the ASB held that it did not encourage excess consumption, even though the size of the bucket shown was 21 pieces of chicken.
Read the ASB’s decision on KFC Buckethead Snapchat.