FTC’s Latest “Marketing Violence to Children” Report

by on April 12, 2007

Since 2000, the Federal Trade Commission (FTC) has surveyed the marketing and advertising practices of major media sectors (movies, music and video games) in a report entitled Marketing Violent Entertainment to Children. (The reports can be found here). According to the agency, the purpose of these reports is to examine “the structure and operation of each industry’s self-regulatory program, parental familiarity and use of those systems, and whether the industries had marketed violent entertainment products in a manner inconsistent with their own parental advisories.” The fifth report in this ongoing series was released today.

Generally speaking, the latest report finds that things continue to improve in all three sectors with the greatest improvements coming in the video game sector. But the FTC argues that these industries still need to do more to improve their ratings systems and the enforcement of those systems.

Many of the FTC’s recommendations are unobjectionable in that they are basically suggesting these industries do a better job promoting and enforcing their own voluntary ratings and labeling systems. It’s tough to be against that, of course, but there are some interesting questions about what it means in practice.


For example, one of the things that the agency stresses is the need for all three sectors to consider featuring all their rating and labeling information “prominently on the front of product packaging to make that information more visible for parents at the point of purchase.” Well, that’s already done in most cases, but even when it isn’t parents can always just flip the box over and usually find the information on the back. Is it too much to ask for parents to do that? The FTC seems to imply that the sticker on the front of the package needs to take up a lot more real estate. But how much is enough? Should the rating and labels cover 25% of the cover? 50%? More? Do I hear brown paper bag wrappers, anyone?

Here’s another interesting thing that this report doesn’t really discuss: All these things – - CDs, movie tickets, DVDs, video games – - cost money! CDs cost almost $20 bucks; DVD’s are $20-$30; video games are $20 to $60. In many ways, the price of these items is the most effective parental control at our disposal. If my kids want these things, they have to get the money from me to buy them. (Isn’t that they way it works in most families, or am I living on a different planet?) So, parents certainly can exercise a great deal of control over their children’s media buying decisions by simply exercising their “power of the purse” and talking to kids about their purchases. But none of this is mentioned in the FTC report.

And that’s what makes the FTC’s use of “mystery shopper” surveys in these reports somewhat problematic. Here’s the way these things work. The FTC hires a firm that recruits a bunch of 13- to 16-year-olds who make an attempt to purchase such games without a parent being present. (Incidentally, where were these “mystery shopper” jobs when I was a teenager? This certainly would have beat sweeping the floors in my dad’s warehouse every summer!)

But do all 13-16 year olds really go into stores and buy games on their own? Are you telling me that parents of 13-16 year olds are never present when these purchasing decisions are being made? I find that very hard to believe. And, again, even if you let your 13-16 year olds wander around malls as they wish, do you stuff wads of cash in their pockets beforehand and tell them to go buy whatever they desire? Moreover, even if you did that, when they come back with a bag from an electronics retailer stuffed with games, movies or music, do you not ask them any questions about it? Come on! This report assumes parents are completely asleep at the wheel and that our kids are left completely free to buy any media they want. That’s just not the way the real world works.

I guess critics could argue that some kids can get access to their parents’ credit cards or somehow use deceit to get money from them to buy these things on their own. And many kids do have their own allowance, of course (but apparently it’s a heck of lot more generous than the allowance I used to get growing up in the 1970s!) But this is all clearly a matter of personal responsibility that parents must deal with in this and many other many contexts. In a free society, government should not use a potential lack of parental responsibility as an excuse for regulatory intervention.

Regardless of all this, the good news is that the FTC’s mystery shopper surveys continue to show signs of improvement. For example, the number of teenagers who were able to purchase “M”-rated (mature) video games as part of the mystery shopper surveys has fallen steadily since the FTC began such surveys in 2000. 85% of teens were able to buy M-rated games that year, but the number fell to 78% in 2001, then 69% in 2004, and now 42% in the 2006 survey. The sale of music with “explicit lyrics” warnings to the mystery shoppers was 85% in 2000, briefly rose to 90% in 2001, but then fell to 83% in 2003 and 76% in 2006. Results for “R”-rated movies on DVD have only been collected for the last two years, but they also improved from 81% in 2003 to 71% in 2006. Cinema ticket sales to minors for R-rated movies has fluctuated from 46% in 2000 to 48% in 2001 to 36% in 2003 but then back up slightly to 39% in 2006.

Clearly, there is room for improvement in all these sectors. But let’s make a few things clear. First, the affected industries must ultimately rely on retailers to enforce their ratings systems. The content creators do take steps to educate content retailers and provide them with educational materials and signage to highlight the industry’s ratings systems and enforce it accordingly. But it will never be possible for these content producers to ever exercise perfect quality control over retailers. Some retailers will do a great job; others will fall down on the job occasionally.

Second, it is important to recall that even if your kids somehow manage to buy a movie or video game rated above their age group, you also have another line of defense once those things are brought into the home: parental control technologies. For example, major game consoles developers (Sony, Microsoft and Nintendo) all include sophisticated parental controls in their new gaming systems. These console controls allow parents to enter the ESRB rating level that they believe is acceptable for their children. Once they do so, no game rated above that level can be played on the console. (All ESRB-rated games contain embedded “flags,” or a string of code in the software, that allow the consoles to automatically recognize the game’s rating). And the same is true of DVDs, which can be blocked on DVD players, personal computers, and gaming consoles using the MPAA ratings designations.

Finally, no matter how good (or how prominent) the industries make their labels and ratings, there will always be a small group of parents who are willing to walk right up to the cash register and hand a salesperson $20 to $60 bucks to buy their kids “Sin City” or “Grand Theft Auto.” And plenty of parents still buy their kids tickets to R-rated movies and walk into the theater with them. In other words, you can lead a horse to water but you can’t always make them drink. Honestly, I don’t know what some of those parents are thinking, but we have to accept the fact there are some parents out there who adopt a veritable “anything goes” approach to their children’s media consumption.

In a follow-up essay, I plan to discuss an additional concern raised by the FTC report: How these industries advertise their content to children on television, in magazines, and on the Internet.

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