Section 14: Independence from External Interests - GuidelinesSection 14.3
14.3.1 We need to be able to reflect the real world and this will involve referring to products and services in our output. A product can include references to organisations, to people, such as artists or performers, or to artistic works, such as films, books or musical tracks. However, there must be no undue prominence of products, services or trade marks in our content. To avoid this we must:
- ensure that visual and aural references, including verbal and musical references, to products, services, trade marks, brand names and slogans are editorially justified
For the meaning of trade mark see Section 14 Independence from External Interests: 14.1.
- make sure that the manner in which the reference is given is appropriate. Any favourable descriptions must be editorially justified. Prices and availability should not normally be discussed outside consumer review content
- avoid lingering on, or showing close-ups of, brand names or logos, and use aural references sparingly unless it is editorially justified to do so
- minimise references in output designed to appeal to children.
The degree of prominence that may be acceptable will depend on the context. A product that is integral to an item may justify a greater degree of exposure. Organisations who are partners must be given due attribution but this must not be unduly prominent.
Use of material from advertising campaigns or promotions must be editorially justified. Normally only a short extract should be selected.
Spoken references to a product or service will generally assume a greater degree of prominence than visual references on their own.
Product Prominence – the cumulative effect
14.3.2 In addition, we must take into account the potential cumulative effect of repetition of a reference when planning to feature a product, brand, trade mark or service many times on our output over a limited period, to ensure that this does not lead to undue prominence. We should include programme repeats and marketing in this assessment. Cumulative effect is likely to be greatest around the time of a new release by brands, such as artists and performers, or products, such as films and records.
When planning to feature a product, service or trade mark over a number of pieces of editorial content (excluding news and current affairs output), broadcast or published in a limited period, such as a single day, referral must be made to the relevant output controller(s) and Editorial Policy who will consider whether any cumulative impact of such references is editorially justified as a whole.
Product Prominence and Interactivity
14.3.3 When we encourage audiences to interact with us, or refer to their comments on air or online, any references to products, such as social media platforms or hashtags, should not be unduly prominent either within a single piece of content or cumulatively.
Any brands and hashtags should be appropriate for the expected audience. With calls to action, platforms we refer to should be free to use. Undue prominence is more likely where a branded platform is referred to without also supplying details of generic means of communication, such as email.
14.3.4 When reporting audience comments we should normally aim to be platform neutral and not attribute each brand every time it is used. We should normally endeavour to offer contributions from a variety of platforms.
Product Prominence in Trails
14.3.5 We should normally avoid references to products or services in programme trails or BBC programme marketing material because the repeated exposure could be unduly prominent. Music in trails may also become unduly prominent if it is around the time of a new release of the track. We should consider the cumulative effect of use of a new release in a trail when it is also scheduled to be performed elsewhere in BBC content. Any reference to a branded product or service in trails should be editorially justified.
Any proposal to use advertising clips in programme trails on Public Services must be referred to the Head of Editorial Standards, Marketing and Audiences who will consider whether the use is editorially justified and not unduly prominent.
Undue Prominence and Contributors
14.3.6 We must avoid undue prominence when contributors discuss their current releases such as a film/music release or launch of a new book or play. Any related products should not be used as a prop unless editorially justified and any references, particularly close-ups, must also be editorially justified and should be appropriately limited.
Reviewing Products or Services
14.3.7 We should not promote products or services when we review them and we should review a range from different suppliers within a programme or series. In the case of books, albums and other digital products we may normally accept copies for review. Those responsible for reviewing or covering theatre, concerts or other events or performances may accept review tickets. We generally buy products of significant value, such as a washing machine or a car, for review. However, if on occasion we are supplied with them, we must return the product to the manufacturer or supplier.
Linked or Embedded Streams from Third Parties
14.3.8 There must be no undue prominence of the third party. [ For Public Services only] On Public Services when a stream has been sponsored, there must be no reference to the sponsor or the sponsor’s products, services or trade marks. [For Commercial Services only] On Commercial Services any reference to a sponsor or their products, services or trade marks may be product placement. However, references must not be promotional.
(See Section 14 Independence from External Interests: 14.3.27-14.3.36, Section 7 Privacy: 7.3.29-7.3.33, Section 16 External Relationships and Financing: 16.3.17-16.3.18 and Section 17 Competitions, Votes and Interactivity: 17.3.53)
Supply of Props in Drama, Comedy, Entertainment or Lifestyle Content
14.3.9 We must ensure the use of, or reference to, branded products, services or organisations in our drama, comedy, entertainment and lifestyle content is editorially justified and that a wide range are used over time to avoid undue prominence.
Any spoken reference accompanying a visual reference must be editorially justified.
When real products are used as set dressing we should try to avoid close ups and we should avoid visibility of them in other shots.
For the meaning of prop placement see Section 14 Independence from External Interests: 14.1.
14.3.10 [For Public Services only] On Public Services, props are not usually accepted without some payment by the BBC. Where possible, BBC productions should use the BBC internal procurement process.
14.3.11 [For Commercial Services only] On Commercial Services there must be no arrangements guaranteeing that placed props will receive exposure in editorial content. If these conditions are met then it will be regarded as prop placement not product placement provided the provision of the prop or service has no more than a trivial value.
Props of significant value may be treated as product placement if they are not returned to the provider.
14.3.12 On Public Services when props are accepted at a reduced cost and on Commercial Services when props are accepted free or at a reduced cost there should be:
- records kept by production of all free or reduced cost props
- no guarantee that any product or service will be featured and, if featured, no guarantee that it will be in a favourable light
- no undue prominence of the prop which has been accepted.
Free and Reduced Cost Facilities, Products and Services
Consumer and lifestyle content which reviews or features a wide range of products may accept free or reduced cost products or services if they are editorially justified and meet appropriate selection criteria. But in such cases production must:
- keep records of what has been accepted
- never promise that any product or service will be featured, and if featured, that it will be in a favourable light
- only accept discounts if these are consistent with discounts offered to other large organisations
- inform suppliers in writing that they cannot refer to the BBC’s use of their products or services in any advertising or promotions
- only give on-air and online credits if editorially justified. [Public Services only] Public Services should never promise to feature a supplier’s details online in return for the supply of free or reduced cost products or services.
14.3.14 No payment must be accepted for products or services to be featured on any BBC service as product placement is prohibited in consumer advice content.
14.3.15 Suppliers must not have an editorial say in the content and should not be given a preview of it.
For makeover programmes see Section 16 External Relationships and Financing.
14.3.16 Where a facility, such as a feed is shared between the BBC and a third party, the BBC must retain editorial control of any ensuing content on BBC services and pay the appropriate portion of the cost.
Media Facility and Fact Finding Trips
14.3.17 On Public Services, and for news and current affairs content on Commercial Services, we should not normally accept expenses-paid trips unless they are the only way to cover a significant event.
14.3.18 Any proposals to accept an expenses-paid trip must meet the BBC’s Anti-Bribery Policy.
In our content we should not normally refer to any commercial operators offering the facility, or to charities and lobby groups. Any reference to other organisations which have facilitated the trip must be editorially justified.
Any proposal to accept an expenses-paid trip must be referred to a senior editorial figure or, for independent production companies, to the commissioning editor who will consider whether:
- the trip, and any references to organisations which have facilitated it, are editorially justified and will not damage the editorial integrity of the BBC
- a contribution should be made towards the cost, where reasonably practicable.
[For Commercial Services only] Staff working for Commercial Services which review a range of services and facilities may seek assistance from travel providers such as tourist boards, airlines and hotels. In such cases:
- there must be no assurances of any coverage in exchange for such services
- information should be published on a range of travel suppliers and not just those who provide us with assistance.
Promotional Material or Stories Supplied by Outside Bodies
14.3.19 We must select and cover stories for our own independent editorial reasons and be alert to situations when organisations may access multiple areas of the BBC by different routes to try to place stories across our services in a limited period.
Online Links to Third-Party Platforms
Links from Public Service platforms and from the editorial content of a Commercial Service platform must be editorially justified.
[For Public Services only] On Public Services, links should lead to third-party sites which, if not free to access, should be labelled as subscription sites.
Logos and Credits Online
Partners should be given due attribution and recognition, including in the branding and promotion of the output and services created or distributed.
Public Service References to BBC Commercial Services and Products and Other Material Related to Editorial Content
Public Service References to BBC Commercial Services
14.3.23 [For Public Services only] We must not use our Public Services to promote any BBC Commercial Services or products. On Public Services all references to BBC Commercial Services such as websites, international channels or any international or UK-based joint venture channels must be editorially justified.
[For Public Services only] However, the BBC, and independent companies working for the BBC, may produce and license programme-related material, which may be promoted during or around the editorial content from which it is directly derived. Any such promotion must be to allow audiences to benefit from or interact with the related editorial content, and must be editorially justified.
For the meaning of programme-related material see Section 14 Independence from External Interests: 14.1.
Trails for Commercial Products Related to BBC Programmes
14.3.24 [For Public Services only] On Public Services we may broadcast trails for some programme-related materials in junctions after the editorial content from which they are directly derived. Online we may link to a page on a commercial site where commercial products related to BBC programmes may be purchased where editorially justified.
[For Public Services only] Any product which is trailed must be under the BBC’s editorial control and must have been commissioned, licensed or developed directly in conjunction with the associated content. Trails or announcements after programmes should be limited to factual information.
[For Public Services only] BBC-branded magazines must not be trailed on BBC Public Services on air or online. For other BBC-related products on radio, see the relevant guidance.
[For Public Services only] (See Guidance: Trails on radio for Commercial Products related to BBC Programmes)
Transactional Links from Public Service Platforms to Commercial Products Related to BBC Editorial Content
BBC Support Services
When we broadcast or publish content raising difficult or distressing issues it may be appropriate to provide an action line offering further information or support.BBC Action Line should normally be consulted for UK-facing content.
Fact packs and other learning support may be provided to complement other content.
The following conditions apply to support services:
- information provided on support services should be duly accurate and impartial
- any external links should be justified by the relevance and value to the audience. We should normally provide links to a range of agencies, charities or statutory organisations which should be chosen using appropriate selection criteria
- we must ensure we can cope with any likely demand for our support services. Any phone line, whether provided by the BBC or an outside agency, should be capable of offering a robust service
- support service phone lines should be free or priced at cost recovery, not designed to make a profit. We must not use premium rate services for action lines
- we must not appear to endorse third-party campaigns when we produce support material in conjunction with other organisations
- we should not distribute third-party fundraising material unless it is for BBC-approved charity appeals
- [For Public Services only] UK Public Service support material online must not be sponsored
- we may credit organisations who have contributed to our support material on the material itself. We may credit the involvement of a partner on air, but [For Public Services only] on Public Services we must not credit sponsors on air
- in the UK we should not normally trail helplines or action lines run by other organisations, except where they offer a specialised service.
For the meaning of product placement see Section 14 Independence from External Interests: 14.1.
14.3.27 [For Public Services only] The BBC must not commission, produce or co-produce output for its UK Public Services which contains product placement. All programmes made by the BBC or an independent producer for broadcast on UK Public Services must be free of product placement.
Any proposal to carry output on UK Public Services which requires signalling for product placement must be approved by the Director-General.
[For Public Services only] For financing of World Service see Section 16 External Relationships and Financing.
[For Commercial Services only] In some cases, BBC Commercial Services may commission or make editorial content which includes appropriate product placement.
Product Placement in UK Public Service Acquisitions from Third Parties with No Connection to the BBC
Acquisitions from outside the UK
14.3.28 [For Public Services only] When a UK Public Service acquires content containing product placement that it has not commissioned or produced and that has not been commissioned or produced by a connected person, such as a BBC Commercial Service, there is no product placement signalling requirement.
For the meaning of connected person see Section 14 Independence from External Interests: 14.1.
[For Public Services only] (See Section 14 Independence from External Interests: 14.1)
[For Public Services only] There must be no conditions attached to the acquisition that the product placement will be broadcast.
[For Public Services only] Any visual or aural mentions of products that have been placed in an acquisition that is not from a connected person should be editorially justified and must not be promotional or unduly prominent.
[For Public Services only] A record should normally be kept of the existence of any product placement where known, and of any measures taken in relation to it.
[For Public Services only] (See Section 14 Independence from External Interests: 14.3.1-14.3.9)
[For Public Services only] Editorial content made after December 2009 and distributed on an Ofcom-regulated service must not contain product placement of any products, services or trade marks prohibited under the Ofcom Code.
Acquisitions from the UK
Any proposal to broadcast/publish a programme that was originally transmitted on a UK commercial service unconnected with the BBC which includes product placement must be referred in advance to the relevant channel controller and to Editorial Policy who will consider whether the product placement:
- is editorially justified
- would bring the UK Public Services into disrepute
- should be obscured or removed.
Product Placement in Live News Broadcasts on UK Public Services
14.3.30 [For Public Services only] There may be occasions when there is placement in a live news feed, such as a feed from the United States at the time of a breaking story. We should not normally broadcast the placement if we know it is present.
Product Placement Requirements for BBC Commercial Services
14.3.31 [For Commercial Services only] All product placement in any editorial content made by any part of the BBC for a BBC service or for any third party, or commissioned or produced by an independent production company for a BBC service, must meet these requirements:
- product placement must not compromise the editorial integrity or independence of the content or BBC service
- no product placement of any product or service may bring the BBC and its services into disrepute
- in services under the BBC’s control, product placement must not influence the content and scheduling of content in a way that affects the responsibility and editorial independence of the broadcaster
- references to placed products, services and trade marks must not be promotional or unduly prominent
- the inclusion of product placement should be signalled to audiences
- product placement must meet the applicable product placement regulation for the territory in which it will be broadcast.
All proposals to include product placement on BBC Commercial Services must be approved by a senior editorial figure, or for independent production companies by the commissioning editor, who will consider whether the product placement would damage the reputation of the BBC.
The senior editorial figure/commissioning editor is responsible for ensuring any relevant onward referrals are made.
Restrictions on Programme Genres Which May Take Product Placement and Types of Product Which May Be Placed
14.3.32 [For Commercial Services only] Product placement must not be included in:
- news and current affairs programmes
- religious programmes
- children’s programmes
- consumer advice content.
For the meaning of consumer advice content see Section 14 Independence from External Interests: 14.1.
14.3.33 [For Commercial Services only] Product placement of the following is prohibited:
- any product or service connected to a political party or political organisation
- any product or service connected to a body associated with faith, religion or equivalent systems of belief
- adult products and services
- tobacco products (including but not limited to cigarettes)
- placement by or on behalf of any undertaking whose principal activity is the manufacture or sale of cigarettes or other tobacco products
- any product or service which may not be advertised on the service.
[For Commercial Services only] Services regulated by Ofcom are prohibited from product placement of the following:
- electronic cigarettes or refill containers
- prescription-only medicines.
[For Commercial Services only] Services regulated by Ofcom are prohibited from product placement of the following in programmes produced under UK jurisdiction:
- alcoholic drinks
- foods or drinks high in fat, salt or sugar
- infant formula (baby milk), including follow-on formula
- all medicinal products.
[For Commercial Services only] Services regulated by Ofcom should check the Ofcom Code for updates.
Transparency and Signalling Requirements
14.3.34 [For Commercial Services only] In content commissioned, produced or co-produced for the BBC the inclusion of product placement should be made transparent to audiences. This should normally be through a list of all placed products in the credits for produced or commissioned programmes and should be done in a neutral, non-promotional manner, similar to other programme credits.
Any local regulations on product placement signalling must always be observed.
BBC Commercial Services Targeted at UK Audiences
14.3.35 [For Commercial Services only] BBC Commercial Services targeted at UK audiences should not normally digitally insert product placement into any content produced by the BBC which was originally made for UK Public Services. Nor should they normally insert product placement into any editorial content made by an independent producer which was originally commissioned for BBC UK Public Services.
Any proposal for a BBC Commercial Service, including but not limited to video on demand, operating in the UK to digitally insert product placement into any content produced by the BBC which was originally made for a UK Public Service or to insert product placement into any editorial content made by the BBC, or by an independent producer, which was originally commissioned for BBC UK Public Services must be referred to Editorial Policy who will consider whether the product placement would damage the reputation of the UK Public Services.
BBC Commercial Services Targeted at Audiences Outside the UK
14.3.36 [For Commercial Services only] Where a BBC Commercial Service or a connected person co-commissions or co-produces a programme with a UK Public Service, the version on the UK Public Service must not contain product placement.
For the meaning of connected person see Section 14 Independence from External Interests: 14.1.