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0 • • Lucy Henke My name is Lucy L Henke and I am an Associate Professor of Marketing at the University of New Hampshire. I received my Ph.D., in Communication Studies from the University of Massachusetts in Amherst, where I developed a nonverbal methodology for assessing young children's perceptions of television advertising. I have authored or coauthored numerous articles on children's perceptions of advertising which have been published in peer reviewed journals including the Journal of Advertising Research, the Journal of Marketing, the Journal of Advertising, the Journal of Child Study and, the Journal of Broadcasting and Electronic Media. I have also presented several papers on children and advertising at national academic conferences. I am currently working on a study of children's perceptions and use of the Internet. I have conducted advertising tracking studies, feasibility studies, and other types of consumer research for several major national corporations. I have taught at the University of Kentucky, The College of William and Mary, and the University of Lowell in Massachusetts, where I was a tenured Associate Professor of Marketing. A copy of my curriculum vitae is attached. I have reviewed FDA's proposed regulation, and am providing comments on Part V, Section III, Subpart D, Section 4 (Fed. Reg. 41332), the "Empirical Research on the Effects of Cigarette Advertising Activities on Young People," and Section 5 (Fed. Reg. 41334) the "Summary of Evidence" of the FDA proposed "Regulations Restricting the Sale and Distribution of Cigarettes and Smokeless Tobacco Products to Protect Children and Adolescents." Section 5, Summary of Evidence, concludes that studies of cigarette advertising suggest "a causal relationship between advertising and youth smoking behavior" (Fed. Reg. 41334), that industry actions have "resulted in attracting children" (Fed. Reg. 41334), and that "cigarette advertising and promotion play an important role in encouraging young people to start smoking" (Fed. Reg. 41334). In reaching these conclusions, the agency has relied on findings from studies of teenagers by Gallup (1992, footnote 150, Fed. Reg. 41344), and Pierce (1991, footnote 151, Fed. Reg. 41344), for the proposition that "even relatively young children are aware of cigarette advertisements and can recall salient portions" (Fed. Reg. 41332), and that "12- to 13- year-old California children surveyed could name a brand of cigarettes that was advertised" (Fed. Reg. 41332). The agency also cites in its document, in support of the conclusions in Section 5, the findings of studies by Fischer (1991, footnote 168, Fed. Reg. 41345) and Mizerski (1994, footnote 169, Fed. Reg. 41345), which discuss recognition rates for Joe Camel among young children (Fed. Reg. 41333). Based in part on the findings of the studies mentioned above, the FDA concludes that there is "compelling evidence that promotional campaigns can be extremely effective with young people." The studies FDA cites simply do not support FDA's conclusion regarding the effect of promotional campaigns on young people. These studies support very simple, basic concepts which do not justify the great leap of faith to the conclusion reached

0 • by the FDA. FDA has completely ignored the entire body of relevant advertising research in this area. What the FDA should have considered in reaching its conclusions about children's perceptions of cigarette advertising is the following information: I. Children are fairly sophisticated consumers who learn about the persuasive intent of advertising at an early age and become skeptical, even cynical, about advertising well before they become teenagers. II. "Awareness" of a brand is not equal to "purchase" of a brand. There are several stages in the complex consumer decision-making process between awareness and purchase, during which information about the product is acquired from a variety of sources, and evaluated before it is ever acted upon. The fact that children may be "aware" of advertised logos does not in any way mean that they intend to use or are even thinking about using the products in the advertised product category. In fact, we know from extensive experience, research and observation that children acquire a substantial amount of information about cigarettes from a variety of sources, evaluate the information about the product category as negative, and decide to avoid cigarettes and smoking. Ill. Parents, peers and authority figures to children play an important role in mediating information about smoking that children receive. These sources constantly warn children not to smoke. Commercial advertising is only one of many information sources available to individuals to consider in making decisions to purchase or not to purchase products, and it is one of the least credible. Parents and peers have been shown to play a determining role in the decisions about many products, including cigarettes. In fact, parents use well- known cigarette logos to initiate discussion with their young children about the dangers of smoking. Following is an explanation of the above remarks. I. Children are fairly sophisticated consumers who learn about the persuasive intent of advertising at an early age and become skeptical, even cynical, about advertising before they become teenagers. In the early 1970s, in response to the demands of Action for Children's Television ("ACT') and other pressure groups, the FTC launched an investigation into children's perceptions of advertising, focusing especially on whether children were particularly "vulnerable" to advertising. ACT and others claimed that because children did not understand that the purpose of advertising was to sell goods and services, children were therefore not poised to defend themselves against the "persuasiveness" of advertising claims. Initial research appeared to support the claims of ACT by 2

0 providing evidence that children who attributed persuasive intent to advertising tended to like ads less, to trust them less, and to be less likely to express a desire for the • advertised product (Robertson and Rossiter 1974). The FTC investigation of this "defenseless consumer" argument raised two central questions: First, do children have the ability to distinguish between program content (or editorial content) and ads? Second, do children have the ability to identify • the commercial intent of ads? The research which addressed the two issues sought to determine the age at which children developed each of the abilities. Following are findings related to research on these two central issues. • A. Even young children are able to, and do, distinguish between program content and advertising content. In their studies of children from the ages of 5 to 12, Blatt, Spencer, and Ward (1972), Ward, Reale and LeVinson (1972) and Ward and Wackman (1973) (all cited in Adler, 1980) found that the ability to distinguish program content from advertising • content increased with age. Older children (9- to 12-year-olds) were able to "verbalize" the differences between commercial ads and program content. Younger children (5- to 8-year-olds) in the studies demonstrated lower levels of ability to differentiate between programs and ads in response to the open-ended measures used in the studies, which required the children to verbalize an explanation in • response to the question 'Why are commercials shown on TV?" A number of researchers began to build upon the methodology used in some of the early studies (Gianinno and Zuckerman 1977 (cited in Adler, 1980); Henke 1980; Donohue, Henke, and Donohue 1980). Because language facility is a complex skill which develops with age, they reasoned, might the reliance on a verbal measure • bias the results of the studies? Young children who have an understanding of the difference between programs and ads (a competence issue) may simply be unable to demonstrate their understanding (a performance issue) using their limited verbal skills to respond to the open-ended question, 'Why are commercials shown on TV?" • Gianinno and Zuckerman (1977) (cited in Adler, 1980) used a nonverbal methodology in their study of the perceptions of children between the ages of 4 and 10. Using photos of animated characters from programs and commercials, they confirmed a finding of previous studies: very young children had difficulty "articulating" in adult language what an advertisement was. However, the researchers found that 0 the same four-year-olds, using the pictorial measure, understood the difference between program content and commercial advertising messages. • In summary, the studies reveal that, using a nonverbal methodology, children ~ • as young as four years of age are able to demonstrate an ability to differentiate o programs from ads. ~ ~ O 3 ~ w cn ~ • o0

a • • 0 ! 0 • B. Even young children understand the persuasive intent of ads. The second issue addressed by the FTC involved the ability of children to "defend" themselves from the persuasive intent of advertising: the research suggested that children who could identify the persuasive intent of ads were less vulnerable to advertising claims (Robertson and Rossiter 1974). Several studies conducted in the early 1970s examined whether children between 5 and 12 years of age were able to articulate an understanding of the selling intent of ads. Ward and Wackman (1973) (cited in Adler, 198C) asked children 'Why are Commercials shown on TV?" and found that older children (9- to 12-year-olds) were able to verbalize an understanding of commercial intent of commercials; younger children (5- to 8-year-olds) were least able to do so. Robertson and Rossiter (1974) confirmed the Ward and Wackman findings regarding older children. They found that 99% of 5th-graders could verbalize the persuasive intent of ads. The Robertson and Rossiter study, however, suggested that younger children understood more than the Ward study had reported: as many as 53% of'the first-graders in the Robertson study were able to verbalize the selling intent of ads. As occurred with regard to the studies of differentiation between ads and programs, researchers questioned whether the reliance on verbal methodologies may have biased the results of the study in favor of older children, who have greater facility with the language. Henke (1980) and Donohue, Henke, and Donohue (1980) assessed the perceptions of children from 3 to 6 years of age using a nonverbal methodology, and found that as many as 75% of 3-year-olds were able to express an understanding of the persuasive intent of ads when the nonverbal measures were used. By the age of six, 96% of children indicated an understanding of selling intent when a nonverbal methodology was used. In summary, the studies confirm that, using a nonverbal methodology, children as young as three years of age are able to distinguish and demonstrate an understanding of the persuasive intent of advertising. ~ C. Children who understand the persuasive intent of ads are more likely to be skeptical, even cynical about advertising. Robertson and Rossiter (1974) demonstrated a relationship between high awareness of motive and lower demand for the products, less trust of ads, and more • negative evaluation of ads. In their study of children's perceptions of advertising during the pre-Christmas season, they concluded that children's ability to attribute persuasive intent to advertisers increased their cognitive defenses against advertising claims. A recent study by Boush, Friestad, and Rose (1994) extends Robertson's ~ attribution theory analysis in their study of adolescents, and finds that adolescents o s knowledge of advertiser tactics is positively related to skepticism toward advertising. ~ ~ 0 4 ~ C3t ~ 1 ~

f • i A study by Bever et al. suggests that one need not wait until adolescence to find the skepticism related to attribution of selling intent. The study of 5- to 12-year- olds by Bever et al. (1975) concluded that by age 10, children believe that advertising is misleading. By age 12, the authors found, children adopt the cynical outlook of tolerating the social hypocrisy of misleading advertising. Therefore, the research clearly demonstrates that even young children have a fairly sophisticated understanding of advertising. They can distinguish ads from other types of content, they understand the persuasive intent of ads, and they therefore become skeptical about advertising before their teenage years. These findings regarding the growing mistrust of advertising claims suggests that children are not "defenseless" in the face of advertising. They evaluate what they have seen in ads in the context of what they have learned from other sources--parents and friends, for example--in drawing conclusions about advertised products. For all of these reasons, FDA does not need to "protect" adolescents and children from the color and imagery of cigarette advertising. II. Awareness of a brand is not equal to purchase of a brand. There are numerous stages in the consumer decision-making process between awareness and purchase, during which information about the product is acquired from a variety of sources, evaluated, and acted upon (Lavidge and Steiner, 1961). In the Fischer study cited by the FDA', children demonstrated a high awareness of Old Joe Camel, and the authors concluded that, therefore, cigarette advertising presented a "risk" to young children. What the authors failed to measure was children's attitudes toward cigarettes and smoking -- a much more relevant inquiry. The fact that children are aware of advertised logos does not mean that `they intend to purchase the brand or use the products in the advertised product category. In fact, young children acquire information about many different products for adults and children. A recent study reported that children between the ages of 3 and 8 had high awareness of Joe Camel but had equally high awareness of the trade characters for several other adult- oriented products as well (Henke, in press). The most important finding was that almost all of the children (97%) reported that they disliked cigarettes and reported that cigarettes are "bad for you." Asked to identify the appropriate target market for cigarettes, none of the children reported that cigarettes were for children. Most reported that cigarettes were for adults, and 27% volunteered that cigarettes were for "nobody." ' Fischer, P.M., et al., "Brand Logo Recognition By Children Aged 3 to 6 Years, Mickey Mouse and Old Joe the Camel," Journal of the American Medical Association, vol. 266, No. 22, pp. 3145-3148, 1991. 5

9 The Henke study, forthcoming in the Journal of Advertising, focuses on the questions most relevant to the FDA proposal and provides the information not examined in the Fischer article so heavily relied on by the FDA proposal. The study findings strongly suggest that, for young children, recognition of cigarette advertising symbols does not result in positive "affect" toward cigarettes or smoking. While recognition of Joe Camel may be high among children ages 3 to 8, recognition of over 20 other logos is also high, and the awareness of logos extends to a wide range of children's and adults' products. To equate "awareness" with positive attitudes or the "intent to consume" the product ignores the body of research about children and advertising and grossly underestimates the abilities of young children to think critically, engage in perspective-taking, and make value judgments. In fact, the study results suggested that characters such as Joe Camel may make the issue of smoking, as an act for adults and not children, more salient for young children and their parents, and may therefore play a role in parental mediation to actually increase and reinforce the understanding that smoking is for adults only. A followup study by Henke and Wolf (1995), described below, provides evidence that parents use cigarette logos to reinforce their lessons to their children about the risks associated with smoking. Ill. Parents play an important role as one of the many sources which serve to influence the develoament of attitudes toward cigarettes and smoking among young children. Many studies provide evidence that young people acquire information about products, including tobacco products, from many sources other than advertising (Stanton and Silva; 1992, Tinsley, 1992; Ward, Wackman and Wartella, 1977). A recent study by Henke and Wolf (1995) assessed parental intervention and parental attempts to influence their young children's perceptions of and attitudes toward smoking. The study confirmed that parents use Joe Camel to teach and reinforce their children's views about the negative effects of smoking, especially if their children have mentioned Joe Camel. Even parents who believe their children are unaware of Joe Camel reported using the trade character to reinforce and repeat discussions with their children regarding the claimed risks of smoking. Therefore, although recognition of Joe Camel, may be high, that awareness is not in any way related to positive affect toward smoking; in fact, in many cases the awareness leads to parental intervention to educate and reinforce young children's views regarding the potential negative effects of smoking. IV. Conclusion The goal of reducing underage smoking is admirable. FDA's proposal to ban color and imagery in advertising for tobacco products as a tool to reduce smoking is, however, destined for failure. The proposal is based on inappropriate conclusions drawn from studies of questionable validity. 6

References • • • • • • • Adler, Richard, G.S. Lesser, L.K. Meringoff, T.S. Robertson, J.R. Rossiter and S. Ward (1980), The Effects of Television Advertising on Children, 32-35, 38-39, 240-241, 266-269, 294-297. Bever, T., M. Smith, B. Bengen, and T. Johnson (1975), "Young Viewers' Troubling Response to TV Ads," Harvard Business Review, 53 (November-December), 109-120, referenced in Adler, Richard, Gerald S. Lesser, Laurene Krasny Meringoff, Thomas S. Robertson, John R. Rossiter, and Scott Ward (", 980), The Effects of Television Advertising on Children, Lexington, Massachusetts: D.C. Heath, 240-241. Boush David M., Marian Friestad, and Gregory M. Rose (1994), "Adolescent Skepticism Toward TV Advertising and Knowledge of Advertiser Tactics," Journal of Consumer Research, vol, 21, (June), 165-175. Donohue, Thomas R., Lucy L. Henke, and William A. Donohue (1980), "Do Kids Know What TV Commercials Intend?" Journal of Advertising Research, 20, 3, 51-58. Henke, Lucy L., "Young Children's Perceptions of Cigarette Brand Advertising Symbols: Awareness, Affect, and Target Market Identification," Journal of Advertising, (in press). Henke, Lucy L. (1980), "A Nonverbal Assessment of Children's Perceptions of Television Advertising," doctoral dissertation, University of Massachusetts, Amherst, referenced in Henke (in press). Henke, Lucy L. and Michelle Wolf (1995), "Parent Intervention to Prevent Smoking: Using Joe Camel to Teach Children About Smoking." Paper to be presented at the 1996 American Academy of Advertising Conference, Van Couver, B.C., March/April. Lavidge, R., and Gary Steiner (1961), "A Model for Predictive Measurements of Advertising Effectiveness," Journal of Marketing, 25, 59-62, in Solomon, Michael R., Consumer Behavior: Buying, Having, and Being, (1994), Boston: Allyn and Bacon, 149-152, 175. • Robertson, Thomas S., and J.R. Rossiter (1974), "Children and Commercial Persuasion: An Attribution Theory Analysis." Journal of Consumer Research 1 (June) 13-20, referenced in Adler, et al., 267-269. Stanton, Warren R. and Phil A. Silva (1992), "A Longitudinal Study of the Influence of p • Parents and Friends on Children's Initiation of Smoking," Journal of Applied v~ 423-434. Developmental Psychology 13 ~ , ® ~ ca C3~ 00 0 • 7 t.'

0 • • • • • 0 0 . Tinsley, Barbara J. (1992), "Multiple Influences on the Acquisition and Socialization of Children's Health Attitudes and Behavior: An Integrative Review," Child Development, 63, 1043-1069. Ward, Scott and D.B. Wackman and Ellen Wartella, (1977), "Influences on Children's Consumer Learning," How Children Learn to Buy, Beverly Hills, Calif.: Sage Publications, 145-162. ~ 0 ~ 0 ~ w ~ 8 °° w