ASA: Stay honest, legal, and truthful this Xmas or else

Brands are being warned not to get carried away this Christmas, with the Advertising Standards Authority urging caution over seasonal ads – especially for food, betting and booze as well as how they target kids – to ensure advertisers don’t find themselves up before “the beak” in the festive dock.

In a blog post designed to ensure advertisers stick to the rules, the ASA states: “If your marketing menu includes ads for festive foods, your offers can be as generous as Scrooge on Christmas Day, but don’t be a miser with the terms and conditions.

“Ads promoting cheaper foods should make sure the basis of that comparison is fair and supported by accurate evidence. You can avoid misleading consumers by ensuring you’re clear about the nature of your offering, whether that’s the value of a frozen turkey, or making sure your vegan-friendly alternative is just that.”

Meanwhile, the watchdog stresses that “a responsible alcohol ad is not just for Christmas but avoid the temptation to go overboard when tantalising with a tipple. Promoting a ‘barrow of booze’ could lead people to drink to excess and be considered irresponsible”.

It adds: “Alcohol should not be portrayed as a key component in the success of a social event, but that’s not to say your ads should be sober, provided you take care with the presentation.”

Then there are the rules designed to discourage irresponsible Christmas spending using credit, including via Buy Now, Pay Later schemes.

The ASA cites two of last year’s rulings which upheld complaints against ads for Christmas loans. One offered to “Take the stress out of the festive season…” and said customers could “Cherish every moment of the holidays without fretting over your budget”.

According to the ASA ruling, the ad suggested the loan could make Christmas stress-free, and reinforced the impression consumers would, by taking the loan, avoid financial worry, and be able to spend more.

The ASA decided the claims and imagery made light of the decision to take on debt and encouraged overspending. The ad was, therefore, banned for being socially irresponsible; the same conclusion was reached in respect of the second ad.

The watchdog is also keen to flag up the fact that there are plenty of rules in the Codes to protect children from being misled, harmed or portrayed in a sexual manner.

The ASA has, for example, upheld a complaint about a catalogue ad for a “Fire Station” play tent that showed an image of children putting out a real fire. Similar rules prohibit ads for other restricted products, like alcohol, from appealing particularly to children.

For example, for last year’s ad for Bargain Booze, the ASA acknowledged that the fictitious character of Father Christmas has appeal to people of all ages.

However, it considered Christmas, and the traditions surrounding it, were likely to appeal to children and noted that the Bargain Booze ad contained magical elements including a “naughty or nice” barometer, which they considered children might have an affinity with, and found the ad in breach on that basis.

The watchdog concludes: “Without wishing to channel our inner Scrooge, it’s important for us to remind you that the Advertising Codes apply all year around. Christmas is no exception. [Just] ensure its ‘Christmas as usual’ for your 2025 festive campaigns.”

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