Tobacco Documents Online

Office of the Secretary Federal Trade Commission File ~o. File ~Oo 2.0g-~ SIJMMARY COMMENTS OF THE AMERICAN ASSOCIATION OF ADVERTISING AGENCIES REGARDING THE COB~ISSION STAFF REPORT ON CIGARETTE ADVERTISING ~ INC, The American Association of Advertising Agencies, Inc., because of its membership's continuing interest in events of significance to the advertising industry and its involvement with cigarette advertising, presents its view that the Federal Trade Commission should not approve recommendations in. the Staff Report on the Cigarette Advertising Investigation. This position is supported by the following facts: I. The Commission's attempt to impose undue restric- tions • on the freedom to advertise honestly and freely violates the First Amendment privileges legal to advertise any good or service to the same extent that it is legal to sell that good or service. 2. ~e Co~ission's basis for involvement -- deception ;l~ by omission -- is supported neither by Staff- conducted research nor by current consumer behavior. 3. Advertising in the tobacco sector serves above all to promote brands and does not have a significant influence on totml consumption, just as the absence of advertising does not prevent consumption increase. ZT.t T!05390047

Office of the Secretary Federal Trade Commission 4. Advertising makes it possible to give information about the characteristics of tobacco products. It has considerably stimulated competition among brands and facilitated new product introductions which differentiate between various nicotine and tar levels. 5. Cigarette advertising now encompasses a variety of creative approaches and is increasingly identified by consumers as a source of product information, particularly concerning new low-tar/ low~nicotine product entries. The more established brands frequently and legitimately utilize image- oriented "lifestyle" advertising to create brand preferences and to complement the "good taste" message communication in the advertising. 6. Approval of the Staff recommendations would represent an unnecessary regulatory imposition on the develop- ment of effective advertising and would be counter- productive to the ve[y nature of advertising as a competitive tool. December 4, 1981 T105390048