Marketing to children is always different because they are far more gullible. FTC Commissioner Roscoe B. Starek summed up the FTC’s positions in 1997, noting the controlling influence of Central Hudson as reaffirmed by 44 Liquormart and going on to make a case for a compelling government interest in limiting the power of advertisers to target children. But the anti-regulatory climate of the late 1970s through the 90s led to a flourising of deceptive practices, such as encouraging children to use a 900 number to call their favorite cartoon characters or the Joe Camel ads.
Advertisers should take special care not to misrepresent a product or its performance when advertising to children. The Children’s Advertising Review Unit (CARU) of the Council of Better Business Bureaus has published specific guidelines for children’s advertising that you may find helpful.